The Supreme Court said Tuesday investigators don’t have to read Miranda rights to inmates during jailhouse interrogations about crimes unrelated to their current incarceration.
The high court, on a 6-3 vote, overturned a federal appeals court decision throwing out prison inmate Randall Lee Fields‘ conviction, saying Fields was not in “custody” as defined by Miranda and, therefore, did not have to have his rights read to him.
“Today, for people already in prison, the court finds it adequate for the police to say: ‘You are free to terminate this interrogation and return to your cell,’ ” Justice Ginsburg said in her dissent. “Such a statement is no substitute for one ensuring that an individual is aware of his rights.”
Previous court rulings have required Miranda warnings - that a suspect be told he has the right to remain silent and to have a lawyer - before police interrogations for people who are in custody, which is defined as when a reasonable person would think he cannot end the questioning and leave.
Fields was serving a 45-day sentence on disorderly conduct charges when a jail guard and sheriff’s deputies removed him from his cell and took him to a conference room. The deputies, after telling him several times he was free to leave at any time, then questioned him for seven hours about accusations that he had sexually assaulted a minor. Fields eventually confessed and was convicted of criminal sexual assault.
Fields was then sentenced to 10 to 15 years in prison, but appealed the use of his confession, saying that he was never given his Miranda rights on the sexual-assault charges. On appeal, the 6th U.S. Circuit Court of Appeals in Cincinnati threw out his confession and conviction, a ruling that the Supreme Court overturned.
“Not all restraints on freedom of movement amount to custody for purposes of Miranda,” Justice Alito said.
Questioning an inmate doesn’t bring the “shock” of arrest that free people experience and the coercive pressure that follows, Justice Alito said. There is also no hope for a quick release if the inmate talks to police, like there would be for a free person, and there is also no chance of a lighter sentence or any type of reprisal for not talking because the person is already in prison, he said.