Concerning the Miranda custody, if a case is to be decided on two grounds one, which involves a constitutional question and the other a question of general law, the court, is to decide on the ground of general law. In Howes v. Fields, the court did not follow this principle. Fields maintained that he never received any warnings as prescribed by Miranda. In its ruling, the Supreme Court made several explanations. First, the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) excluded the habeas relief because the court’s rejection of fields’ claim was not contrary to unreasonable application of law. The inmate interrogation was not custodial, and so the use of the inmate’s statements was in line with Miranda.  This case presents the willingness by the courts to overlook principles when interpreting constitutional provisions.

Randall Fields was already in jail serving a sentence when he was locked in a conference room and interrogated for more than five hours. The questioning concerned allegations that before his current imprisonment he had sexually abused a child. The Deputy Sheriffs did not read him his rights rather they told him that he was free to return to his cell anytime. Eventually, Fields’ confessed and was confined back to his cell. The state charged Field with sexual conduct introducing his confession, but field claimed that the use of his confession would violate Miranda. The case was a constitutional matter since unless the right to consult an attorney and to remain silent is granted to an object of a custodial interrogation, Miranda rule condemns the use of that objects response against him/her in trial. The trial overlooked this principle and went ahead to convict Field on the ground that at the time of his interrogation, Fields was not in custody and so Miranda posed no barrier to the use of his confession.

Fields filed for habeas relief, and the District Court awarded relief since he satisfied § 2254(d)(1)’s. The panel held that in Mathis v. United States the Supreme Court applied Miranda and held that a warning is required when an imprisoned individual is isolated from other prisoners for purposes of interrogation. Fields was taken to the conference room away from other prisoners and interrogated and thus fits this rule. The Supreme Court held that a prisoner who meets the Miranda requirements should not be taken outside the scope of Miranda just because of his imprisonment. However, given that Fields was reputedly reassured that he is free to leave the well-lit interrogation room, was not physically restrained and the room was averagely sized, then by the definition of Miranda, Fields was not in custody.

Fields was being interrogated by two deputy sheriffs in a conference room. Though repeatedly reassured he was free to leave, he did not request the interrogation, and the sheriffs were armed, and the interrogation lasted for far too long. Justice Ginsburg argued that had the case been in court on direct review rather than habeas petition, she would have ruled that Miranda excluded the use of his testimony in court. The Harvard law review concurs with the ruling of the Supreme Court on the grounds of constitutional interpretation. Contrary to my analysis, the review does not put into consideration that the Supreme Court never considered the element of coercion. Fields could have been coerced to confess.

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