In Howes v. Fields, the Court held that Miranda warnings are not always necessary when police officers interrogate prisoners about events that occurred outside the jail. In this landmark case, the Court seems to take a distinctly different approach to Miranda, its original philosophy, and the Court‘s own earlier case law.
In Howes v. Fields a prisoner was taken aside and questioned about a prior offense without being advised of his Miranda rights. The defendant confessed after five to seven hours of questioning. He was then charged with the crime and his confession was used as evidence against him. The Defendant argued that the confession was inadmissible because it was obtained in violation of his Miranda rights.
The Supreme Court disagreed.
The Miranda warning originates from the 1966 Supreme Court case Miranda v. Arizona. Miranda warnings were put in place to counter-balance the inherently coercive and intimidating setting of a custodial interrogation. In Miranda, the Supreme Court held that it was a violation of a person‘s 5th Amendment right against self-incrimination to be interrogated while in police custody without being warned of the right to remain silent.
Under Miranda, if police fail to inform a suspect of their Miranda rights, any confession or incriminating information stemming from a custodial interrogation is inadmissible in court. Miranda warnings are only required when a suspect is being (1) interrogated by a known state agent (2) while in custody which would seem to clearly include interrogation of prisoners.
While it may seem that being incarcerated is the ultimate form of custody, the Supreme Court in Howes held that imprisonment alone does not rise to the level of custody for Miranda purposes. The Court reasoned that custody, when it comes to prisoners, does not depend on whether the individual is incarcerated, but whether there exists the “coercive pressure that Miranda was designed to guard against.”
The Court did not find that “coercive pressure” in this case. The opinion argued that the questioning of a prisoner did not create the same distress that an initial arrest would, and by consequence, would not have the same coercive pressure on the individual.
Moreover, the Court explained that a recent arrestee and a prisoner have different expectations during an interrogation. While the arrestee may be prompted to answer questions in the hopes that he or she will be allowed to return home quickly, the prisoner has no similar expectations and is therefore not pressured to speak.
Finally, the Court distinguished a prison interrogation from an initial arrest interrogation in that the prisoner knows that his interrogators have no power to grant parole or affect the duration of his sentence. In prison situations, it is unlikely that the prisoner will be motivated to say something to please the interrogators, and therefore the Court concluded that the coercive atmosphere that Miranda was set in place to guard against is absent.
In sum, even though the Court seemed to find support for its ruling in Howes among its earlier cases, the truth is that this case marks a dramatic reduction of Miranda protections. By changing the meaning of custody, the Court has opened the door for potentially abusive interrogation of prisoners without the even nominal cautions afforded by Miranda.