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U.S. Supreme Court: State Prisoner Questioned by Police in Prison Not in Custody for Miranda Purposes

The highest court in the land -- the United States Supreme Court -- has recently ruled that an inmate in state prison, who was questioned by police about criminal offenses he committed prior to entering the prison facility, was not in custody for purposes of Miranda v. Arizona.

The high Court's decision, Howes v. Fields, arises out of the state of Michigan. Defendant Fields was a Michigan state prisoner; he was escorted from his prison cell to a conference room and questioned by law enforcement officers relative to crimes he purportedly committed before being sentenced to state prison. He was never administered his Miranda warnings, nor was he advised that he did not have to speak with the officers during the five to seven hours of questioning. The defendant was, however, advised on more than one occasion that he was free to leave and return to his cell. He was never restrained, and the door to the conference room remained open at times. The defendant eventually confessed to the crimes for which he was being questioned, and he later moved to suppress the confession under Miranda.

The trial court denied the motion to suppress and defendant was convicted. The Michigan Court of Appeals affirmed. Eventually, the federal District Court for the Eastern District of Michigan held that the interview was, in fact, custodial interrogation within the meaning of Miranda, finding that removing defendant from the general prison population, combined with questioning him about prior criminal activity, rendered the interrogation custodial per se (i.e., custodial questioning on its face). The Supreme Court disagreed, ruling that neither Miranda, nor the cases which followed it, held that imprisonment alone amounts to custody for Miranda purposes. The Court found that questioning an individual already in custody does not generally involve the shock that is associated with an arrest, and a state prisoner is not likely to be enticed into speaking as a quid pro quo for early release. Likewise, while isolating a non-prisoner for questioning may help to create a coercive atmosphere, this concern does not generally apply to a prisoner who is, by definition, already isolated by virtue of being in prison. Therefore, according to the Court, serving a prison term, without more evidence of coercion, is not enough to constitute Miranda custody.

It is important to note that Howes v. Fields was decided under a federal constitutional analysis. It is well settled, however, that a state's high court may afford an accused in a criminal proceeding greater constitutional protections under its state constitution than might be afforded under the federal constitution. In other words, the United States Constitution functions as a floor, rather than a ceiling, when it comes to protecting fundamental constitutional rights. It is entirely plausible, therefore, that if a case similar to Howes were to come before the New Jersey Supreme Court at some point down the road, New Jersey's highest court may very well part company with its federal counterpart, and rule quite differently.

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