Close a Miranda loophole

A case to be argued before the Supreme Court on Tuesday poses the question of whether a prisoner must be advised of his rights when he is interrogated inside prison walls. The court should answer yes and close an unconscionable loophole in the Miranda rule.

Randall Lee Fields was in jail for disorderly conduct when he was taken by a corrections officer to a locked conference room. He was then questioned about his relationship with a man named Travis Bice, whom he had met when Bice was a minor. Fields was not read his Miranda rights, which would have told him of his right to remain silent and his right to a lawyer, and was told he could leave the conference room at any time. Fields confessed to engaging in sexual acts with the minor and was eventually convicted of criminal sexual conduct.

When Fields appealed, a Michigan court held that, while he was clearly in custody — which is when the requirement usually kicks in — Miranda didn’t in fact apply in this case. Its reasoning was that there wasn’t a connection between Fields’ custody and the crime he was being questioned about. That was inconsistent with a 1968 Supreme Court decision in which the court said that a Miranda warning was required regardless of why the suspect was in custody.

When Fields petitioned for a writ of habeas court from a federal court, he was more successful. Citing past decisions, the U.S. 6th Circuit Court of Appeals held that Fields had indeed been in custody and offered what it called a bright-line rule: “A Miranda warning must be given when an inmate is isolated from the general prison population and interrogated about conduct occurring outside the prison.”

Since the case of Miranda vs. Arizona was decided in 1966, police and prosecutors — sometimes with the acquiescence of the Supreme Court — have sought to evade its requirements or exploit what seemed like loopholes. A typical tactic is to pretend that a suspect wasn’t really in custody when he was questioned. But the Supreme Court has made clear that a suspect doesn’t have to be in a police station to be in custody. Last term it dealt with a Miranda case arising from the questioning of a minor in school; it held that the age of a suspect must be taken into account when determining whether he or she is “in custody.”

Miranda remains controversial because much of the public thinks it prevents police from obtaining valuable information about crimes. That is the case in some circumstances, but the rule also prevents coerced confessions and, equally important, protects evidence gathered after the warning is issued from legal challenge. The rule should be enforced every time someone is taken into custody, including in prison.