Miranda warnings for inmates

1. This Court’s precedents do not clearly establish the categorical rule on which the Sixth Circuit relied. The Court has repeatedly declined to adopt any such rule. See, e.g., Illinois v. Perkins, 496 U. S. 292. The Sixth Circuit misread Mathis, which simply held, as relevant here, that a prisoner who otherwise meets the requirements for Miranda custody is not taken outside the scope of Miranda because he was incarcerated for an unconnected offense. It did not hold that imprisonment alone constitutes Miranda custody. Nor does the statement in Maryland v. Shatzer, 559 U. S. ___, ___, that “[n]o one questions that [inmate] Shatzer was in custody for Miranda purposes” support a per se rule. 2. The Sixth Circuit’s categorical rule—that imprisonment, questioning in private, and questioning about events in the outside world create a custodial situation for Miranda purposes—is simply wrong. 3. When a prisoner is questioned, the determination of custody should focus on all of the features of the interrogation. The record in this case reveals that respondent was not taken into custody for Miranda purposes. While some of the facts lend support to his argument that Miranda’s custody requirement was met, they are offset by others. Most important, he was told at the outset of the interrogation, and reminded thereafter, that he was free to leave and could go back to his cell whenever he wanted. Moreover, he was not physically restrained or threatened, was interviewed in a well-lit, averagesized conference room where the door was sometimes left open, and was offered food and water. 617 F. 3d 813, reversed.

Result

Reversed

The Court said judges must consider the whole interview when deciding whether a prisoner was in custody for Miranda warnings. It noted that Fields could end the interview and return to his cell, and that he was not restrained or threatened.

Lower courts must assess all the circumstances of a prisoner's interview instead of treating incarceration alone as enough to require Miranda warnings.