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    Howes v. Fields – Understanding Miranda Rights

Howes v. Fields – Understanding Miranda Rights


The Supreme Court has handed down a new ruling in Howes v. Fields that strikes another blow at Miranda rights. If an inmate is already incarcerated, a jailhouse interrogator is no longer required to read the prisoner their Miranda rights. The 6-3 decision overturns a 6th Circuit Court of Appeals ruling that threw out Randall Lee Fields’s conviction when he eventually confessed to and was convicted of sexual assault charges that carried a sentence of 10-15 years.

The majority focused their attention on the “shock of the arrest” and the idea that if the detained individual speaks to the officer, they’ll get out of the arrest or receive some leniency. Because the individual is in jail, the Court reasoned that the same thought process isn’t presented, simply informing the prisoner that “You are free to terminate this interrogation and return to your cell” is sufficient.

Ginsburg Not So Sure

However, for Justice Ginsburg, who wrote the minority opinion, these were the “wrong question[s]” to focus on” She looked at three aspects: was it a “police dominated atmosphere…was he placed, against his will, in an inherently stressful situation…and [were] his ‘freedoms of ‘action’ any significant way.” Ginsburg continued and said those were the fundamental questions that needed answering when determining whether Miranda rights should be read.

Miranda Scope Narrowed by Roberts?

Howes v. Fields is the latest in a string of rulings from the Roberts Court that has narrowed the scope of Miranda, making it more law enforcement friendly. A famous example of this came in 2010 with Berghuis v. Thompkins, where the Court ruled that to invoke your right to remain silent, given by Miranda, a suspect must speak and indicate that they are invoking that right.

In the past two years, the Court has accelerated a pro-law enforcement trend in deciding Miranda rights, and today’s ruling continues that trend. Miranda was a tool that citizens could use to prevent themselves from being taken advantage of by the police. Still, with increasing exclusions being carved out, it is beginning to lose effectiveness and only serves to create more confusion for citizens.


Michael Ehline

Michael Ehline is an inactive U.S. Marine and world-famous legal historian. Michael helped draft the Cruise Ship Safety Act and has won some of U.S. history’s largest motorcycle accident settlements. Together with his legal team, Michael and the Ehline Law Firm collect damages on behalf of clients. We pride ourselves on being available to answer your most pressing and difficult questions 24/7. We are proud sponsors of the Paul Ehline Memorial Motorcycle Ride and a Service Disabled Veteran Operated Business. (SDVOB.) We are ready to fight.

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