Nonetheless, while serving a sentence in jail, Fields was
questioned about alleged sexual conduct with a minor. He was not first advised
of his Miranda rights. The lower court, advancing a categorical rule that (1)
imprisonment, (2) questioning in private, and (3) questioning about events in
the outside world created a "custodial" situation for Miranda
purposes found a Miranda violation.
For the following
reasons, the Supreme Court ruled that this rule did not represent a correct
interpretation of Miranda case law. (1) Under existing law, imprisonment alone
is not enough to create a custodial situation for Miranda purposes. Rather, the
imprisonment must be such that a reasonable person would not feel he was at
liberty to terminate the interrogation and leave. (2) Questioning in private
does not convert a non custodial situation to one requiring Miranda advisement.
Quite the opposite–in the context of a jail setting, rather than removing a prisoner
from a supportive atmosphere, a concern addressed by the Miranda court,
questioning the inmate in private may serve to protect him from other inmates.
(3) Finally, questioning about outside activities does not result in Miranda
custody. Although the questioning may ultimately result in additional criminal
liability, it would do so no more than questioning about criminal activity
within the jail.
© 2011 Darren Chaker. All Rights Reserved.
