Carol Howes, Warden, Petitioner v. Randall Lee Fields (565 U.S. 499)
U.S. Supreme Court · decided February 21, 2012 · Supreme Court Database (Spaeth)
- Citation
- 565 U.S. 499 · 132 S. Ct. 1181
- Decided
- February 21, 2012
- Term
- October Term 2011
- Vote
- 6–3
- Majority author
- Justice Alito
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Alito delivered the opinion of the Court. The United States Court of Appeals for the Sixth Circuit held that our precedents clearly establish that a prisoner is in custody within the meaning of Miranda v. Arizona, 384 U. S. 436 (1966), if the prisoner is taken aside and questioned about events that occurred outside the prison walls. Our decisions, however, do not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provides a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U. S. C. § 2254(d)(1). Indeed, the rule applied by the court below does not represent a correct interpretation of our Miranda case law. We therefore reverse. I While serving a sentence in a Michigan jail, Randall Fields was escorted by a corrections officer to a conference room where two sheriff’s deputies questioned him about allegations that, before he came to prison, he had engaged in sexual conduct with a 12-year-old boy. In order to get to the conference room, Fields had to go down one floor and pass through a locked door that separated two sections of the fa-eility. See App. to Pet. for Cert. 66a, 69a. Fields arrived at the conference room between 7 p.m. and 9 p.m. and was questioned for between five and seven hours. At the beginning of the interview,…
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