Howes v. Fields, No. 10-680 (U.S. Supreme Court) (565 U.S. 499; 132 S.Ct. 1181) (February 21, 2012) (Justice Alito)
Loaded on March 5, 2012
published in Punch and Jurists
March 05, 2012
Filed under:
Punch And Jurists,
Custodial Interrogations.
Here a divided Court held that the prisoner was not entitled to receive any Miranda warnings in advance of a lengthy and coercive prison interrogation on the grounds that imprisonment alone is not enough to trigger a custodial interrogation under Miranda.
In a decision that signals a significant …
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More from this issue:
- Al-Zahrani v. Rodriguez, No. 10-5393 (D.C. Cir.) (669 F.3d 315) (February 21, 2012) (Judge David B. Sentelle)
- In Re Grand Jury Subpoena, No. 11-12268 (11th Cir.) (670 F.3d 1335) (February 23, 2012) (Judge Gerald B. Tjoflat)
- Doe v. Jindal, No. 11-554-BAJ-SCR (M.D.La.) (853 F.Supp.2d 596) (February 16, 2012) (Judge Brian A. Jackson)
- Messerschmidt v. Millender, No. 10-704 (U.S. Supreme Court) (565 U.S. 535; 132 S.Ct. 1235) (February 22, 2012) (Justice (John G.) Roberts)
- U.S. v. Silva-De Hoyos, No. 11-51177 (5th Cir.) (702 F.3d 843) (December 17, 2012) (Judge Priscilla R. Owen)
- Kawashima v. Holder, No. 10-577 (U.S. Supreme Court) (565 U.S. 478; 132 S.Ct. 1166) (February 21, 2012) (Justice Thomas)
- Howes v. Fields, No. 10-680 (U.S. Supreme Court) (565 U.S. 499; 132 S.Ct. 1181) (February 21, 2012) (Justice Alito)
More from these topics:
- Washington Supreme Court Announces Race and Ethnicity Are Relevant Factors Courts May Consider When Applying the Totality of the Circumstances Test for Determining Whether Suspect Is “In Custody” for Miranda Purposes, Feb. 1, 2026. Community Caretaking Exception/Doctrine, Traffic Stops, Self-Incrimination Clause, Custodial Interrogations, In Custody.
- California Court of Appeal Holds Perkins Operation Violated Miranda Where Known Law Enforcement Officer’s “Stimulation” Tactics Amounted to Custodial Interrogation After Suspect Invoked Right to Counsel, Feb. 1, 2026. Confessions - Admissibility, After Request for Counsel, Police Interrogations, Custodial Interrogations, Invocation of Rights.
- Washington Supreme Court Holds Courts Must Meaningfully Consider Youth When Assessing Miranda Waiver and Clarifies That Res Gestae Exception Requires Temporal Proximity to Charged Crime, Feb. 1, 2026. Police Interrogations, Juvenile Offenses/Offenders, Bad Acts Evidence, Custodial Interrogations, Denial of Due Process.
- Colorado Supreme Court Holds Defendant Was in ‘Custody’ for Miranda Purposes Because She Had Hands Bagged and Zip Tied, Commanded Not to Remove Them, and Questioned Alone in Interrogation Room With Door Closed, Feb. 15, 2025. Miranda, Custodial Interrogations.
- Eleventh Circuit Reverses District Court’s Grant of Habeas Relief, Notes It’s ‘Murky on When Putting Two Suspects in a Room Together Qualifies as Interrogation Under Miranda’, July 15, 2024. AEDPA, Miranda, Custodial Interrogations, Minors, Use of, Interrogation.
- Oregon Supreme Court Rules Police Questioning of Probationer in Probation Officer’s Secure Office Absent Miranda Warning Constitute ‘Compelling Circumstances’ and Suppresses Statements, June 15, 2024. Miranda, Custodial Interrogations, Interrogation, In Custody.
- First Circuit: Miranda Waiver Not Valid Where Interrogating Officer Answered ‘No’ to Defendant’s Question — ‘None of this can be used against me, can it?’, March 15, 2024. Miranda, Custodial Interrogations, In-home, Right To Remain Silent, Interrogation, Voluntary Nature/Voluntariness.
- Oregon Supreme Court Clarifies Test to Determine When Person Becomes Agent of the State and Rules Jailhouse Snitch Was Agent, Requiring Suppression of Defendant’s Statements, Jan. 15, 2024. Informants, Post-Arrest Statements, Informants and Paid Witnesses, Confessions - Admissibility, Police Interrogations, Custodial Interrogations, Confessions and Statements of Defendant.
- New Jersey Supreme Court Orders New Trial Because Detective Failed to Clarify Suspect’s Ambiguous Request for Counsel During Interrogation, Sept. 15, 2022. New Trial/Judgment of Acquittal, Custodial Interrogations.
- Vermont Supreme Court: Under Totality of Circumstances, Police Interview of Defendant in Store Parking Lot Was ‘Custodial Interrogation,’ Triggering Requirement for Miranda Warnings, May 1, 2022. Miranda, Custodial Interrogations.