PROTECTING PRISONERS DURING CUSTODIAL INTERROGATIONS: THE ROAD FORWARD AFTER HOWES V. FIELDS

Abstract: In 1966, in Miranda v. Arizona, the U.S. Supreme Court sought to mitigate the inherently coercive atmosphere of custodial interrogations to protect victims from involuntary self-incrimination. In analyzing custody for Miranda purposes, courts look at whether a reasonable person would feel that his freedom of movement had been restricted. When conducting this analysis for a prisoner questioned during incarceration, courts should thoroughly consider the negative psychological effects of prisons in order to understand the prisoner's mindset. The Court had the opportunity to do so in Howes v. Fields, but it instead minimized the coercive effects of prisons. Moreover, the Court's finding that the prisoner in Howes was not in Miranda custody is inconsistent with its past holdings. This Note argues that, in the future, courts should consider with greater nuance the negative effects of prisons in order to protect prisoners from making involuntary confessions.IntroductionOn the night of December 23, 2001, officers took Randall Lee Fields from his jail cell; he did not know where he was being taken or for what purpose.1 He was serving a forty-five day sentence at the Le- nawee County Sheriff's Department for disorderly conduct.2 A jail guard and two sheriff's deputies escorted Fields, dressed in his orange jumpsuit, from the jail to the sheriff's department in the same build- ing.3 The deputies ushered Fields down a flight of stairs and through a locked door that separated the jail and the sheriff's department.4 The deputies then took Fields into a locked conference room in the admin- istrative section of the jail and interrogated him about allegations of sexual conduct that had occurred outside the prison.5 The deputies did not give Fields a Miranda warning, nor did they warn him that he was a suspect in their investigation.6 Fields believed that he was required to speak with the deputies, and was not told otherwise.7 In fact, Fields stated multiple times that he didn't want to speak with the deputies any longer.8 The deputies subsequently extracted an incriminating state- ment from Fields.9Although Fields was not restrained during the interrogation, the deputies were armed.10 He was frightened during the interrogation when Deputy Batterson swore at him, commanding that he "sit [his] fucking ass down."11 During the interview, Fields "became agitated and began to yell."12 Despite being told he could return to his cell at any time, Fields did not feel that he had the freedom to leave.13 Deputy Bat- terson admitted that Fields "could not have just gotten up and walked out of the room."14 Moreover, an immediate return to his cell would not have been possible because he had to wait for the corrections offi- cer to escort him, which would have taken approximately twenty min- utes.15 Fields had never been in that part of the jail before and did not know how to get back to his cell.16The interrogation began sometime between 7:00 p.m. and 9:00 p.m.17 Although the standard bedtime for prisoners was 10:30 p.m., and although Fields was scheduled to wake up to take a dose of his medication at 5:00 a.m., he was not escorted back to his cell until 2:00 a.m.18 Further, as a result of the interrogation, Fields did not receive his nightly dose of medication.19 Overall, the questioning lasted between five and seven hours.20 One of the deputies said the length of this in- terrogation was not unusual, but that he had never participated in one of that length.21After the officers obtained a confession from Fields, the interroga- tion ended and he was returned to his cell.22 He confessed to engaging in sexual acts with a twelve-year-old boy.23 Fields was convicted of crimi- nal sexual conduct and sentenced to a term of ten to fifteen years of imprisonment.24* * * * *The facts of Howes v. Fields, are not uncommon; in many cases, the defendant prisoner is isolated from the general prison population, questioned about conduct occurring outside the prison, and induced into making inculpatory statements without receiving Miranda warn- ings. …