Yesterday, the Supreme Court, in a 6-3 decision, reversed the Sixth Circuit in a criminal habeas case concerning the scope of Miranda protections. Howes, Warden v. Fields. The case involved the question of whether a prisoner who is being interviewed regarding other potential crimes was entitled to Mirandaprotections. The Sixth Circuit had previously affirmed the grant of habeas relief because the defendant had not been given Mirandawarnings druing a lengthy interrogation prior to his confession. The Supreme Court rejected this approach, particularly the “categorical” rule that the Sixth Circuit had adopted that the questioning of a prisoner is always custodial when the prisoner is removed from the prison population and questioned about events that occurred outside the prison. This case follows on the heels of another recent Supreme Court reversal of a Sixth Circuit habeas decision that we covered in Bobby v. Dixon.
