Section 2254

Issues

While Randall Fields was incarcerated, officers unaffiliated with the prison questioned him regarding activities unrelated to his incarceration. Fields made incriminating statements to the officers, and was convicted after these statements were admitted into evidence. The U.S. Court of Appeals for the Sixth Circuit granted Fields' petition for habeas corpus relief, holding that the state court decision was in conflict with clearly established Supreme Court precedent forbidding the admission of statements made without the protection of Miranda warnings. The Supreme Court granted certiorari to determine whether a prisoner is "in custody," and thus entitled to Miranda protections, any time the prisoner is separated from the general prison population and questioned. Petitioning Warden Carol Howes contends that habeas should not be granted because the state court’s decision is not in conflict with any clearly established precedent of the Supreme Court. In contrast, Respondent Fields argues that there is a clearly established rule granting Miranda protection to prisoners anytime they are isolated and questioned. Howes maintains that recognizing a Supreme Court precedent requiring Miranda rights to be issued any time a prisoner is questioned will grant prisoners greater protections than those given to ordinary citizens. Fields counters that requiring officers to issue Miranda warnings is essential to protecting prisoners’ Fifth Amendment rights.

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