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, it is no longer required for a jailhouse interrogator to read the prisoner his or her Miranda rights. The 6-3 decision overturns a 6th Circuit Court of Appeals ruling that threw out Randall Lee Fields’ conviction and confession 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 individual being detained just speaks to the officer they’ll either get out of the arrest or receive some leniency. Because the individual is in jail, the Court reasoned, that same thought process isn’t present. Instead, simply informing the prisoner that “You are free to terminate this interrogation and return to your cell,” is sufficient.
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’ curtailed in any significant way.” (this quote needs to be double checked… did it really say “freedoms” with an s and were “freedsoms of action” in ‘’?) Ginsburg continued on and said that those were the real questions that needed answering when determining if Miranda rights should be read or not.
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 actually 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 cases, with today’s ruling continuing that trend. Miranda was a tool that citizens could use to prevent themselves from being taken advantage of by the police, but with an increasing number of exclusions being carved out it is beginning to lose its effectiveness and only serves to create more confusion for citizens.
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