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Scope of Miranda in jail

The Supreme Court agreed on Monday to clarify when prison or jail officials must give an inmate warnings about his rights under Miranda v. Arizona, when they take the prisoner out of a cell for questioning about another crime. The issue arises in a Michigan child sex abuse case, Howes v. Fields (10-680). The Court’s ruling on the case — expected in its next Term — will clarify the scope of the Court’s ruling in 1968 in Mathis v. U.S. That was one of two cases granted review before the Justices began a four-week recess.

In the second granted case, the Court will decide whether an individual convicted of violating a 2006 federal sex offender law has a right to go to court to challenge the U.S. Attorney General’s decision to apply that law to those who were convicted of sex crimes before the law’s enactment. That issue is posed in Reynolds v. U.S. (10-6549). The Court declined to review issues raised in the petition about the constitutionality of the federal law.

The new Miranda case the Court put on its decision docket grows out of an investigation by sheriff’s deputies in Lenawee County, Mich., into a possible sexual abuse of a minor. Randall Fields was in the county jail serving a 45-day sentence for disorderly conduct. He was taken out of his cell, and questioned for perhaps seven hours in a conference room. During the questioning, he was told he could leave, but state courts concluded that he was “in custody” during that interrogation.

However, state courts ruled that, because Fields was questioned about a potential crime other than the one for which he was in jail, and thus there was no connection between the two, the deputies were not required to give him Miranda warnings. That ruling was overturned when Fields took the case on to federal court. The Sixth Circuit Court interpreted the 1968 Mathis decision to mean that “a Miranda warning is required whenever an incarcerated individual is isolated from the general prison population and interrogated, i.e., questioned in a manner likely to lead to self-incrimination, about conduct occurring outside of the prison.”

State officials urged the Supreme Court to rule that such a “bright-line rule” goes beyond what the Court had previously required.

The newly granted sex offender case involves an attempt to challenge the retroactive application of the Sex Offender Registration and Notification Act. That law requires every sex offender to register, and keep the registration current, in any state that has such a registration requirement — as all 50 states do. In early 2007, the U.S. Attorney General issued a rule that the federal requirement would apply to all sex offenders, including those convicted of a crime that required them to register, even if the offense occurred prior to SORNA’s enactment.

In the case of a Pennsylvania man, Billy Joe Reynolds, who pleaded guilty of failing to register and was sentenced to 18 months in prison, the Third Circuit Court ruled that he did not have “standing” to challenge the Attorney General’s rule on the premise that his sex offender conviction had occurred in 2001. The Circuit Court says the law, on its own force, applies to all sex offenders.

The Circuit Courts are divided on that issue. The Justices, in granting review, limited their consideration to whether Reynolds has “standing under the plain reading of the SORNA statute to raise claims concerning the Attorney General’s interim rule and is review by this Court needed to resolve the Circuit conflict?” The U.S. Solicitor General urged the Court to deny review of Reynolds’ petition.

Recommended Citation: Lyle Denniston, Scope of Miranda in jail, SCOTUSblog (Jan. 24, 2011, 10:30 AM),