Howes v. Fields
| Howes v. Fields | |
|---|---|
| Argued October 24, 2011 Decided February 21, 2012 | |
| Full case name | Carol Howes, Warden, Petitioner v. Randall Lee Fields |
| Docket no. | 10-680 |
| Citations | 565 U.S. 499 (more) 132 S. Ct. 1181, 182 L. Ed. 2d 17 |
| Argument | Oral argument |
| Case history | |
| Prior | Jury trial, conviction, and sentencing, People v. Fields, (2002); affirmed, People v. Fields, No. 246041 (Mich. App. May 6, 2004), leave for appeal denied, 689 N.W.2d 233 (Mich. 2004); writ of habeas corpus conditionally granted, Fields v. Howes, Case Number 2:06-CV-13373 (E.D. Mich. 2009); affirmed, 617 F.3d 813 (6th Cir. 2010) |
| Holding | |
| That the Sixth Circuit had misinterpreted Miranda v. Arizona caselaw, and therefore 1) the Sixth Circuit's own rule could not be the basis for granting a habeas corpus petition, as it was not "clearly established federal law", and 2) that the prisoner had not been subject to a custodial interrogation. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Alito, joined by Roberts, Scalia, Kennedy, Thomas, Kagan |
| Concur/dissent | Ginsburg, joined by Breyer, Sotomayor |
| Laws applied | |
| U.S. Const. amend VI, Miranda v. Arizona, 28 U.S.C. § 2254 (habeas corpus) | |
Howes v. Fields, 565 U.S. 499 (2012), was a decision by the U.S. Supreme Court that an interrogation of a prisoner was not a custodial interrogation per se, and certainly it was not "clearly established federal law" that it was custodial, as would be required by the Antiterrorism and Effective Death Penalty Act (AEDPA). Instead, the Court said, whether the interrogation was custodial depended on the specific circumstances, and moreover, in the particular circumstances of this case, it was not custodial (that is, he was not "in custody" in a way that was covered by the Miranda v. Arizona decision). This decision overturned the rule of the Sixth Circuit, and denied the prisoner's habeas corpus petition.