AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law for Jails, Prisons and Detention Facilities
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A prisoner was questioned for between five and seven hours in a conference room at a prison by two deputies who asked him about crimes he was accused of engaging in before his incarceration. He confessed and was later convicted, with the confession admitted into evidence despite the fact that he had been given no Miranda warnings during the questioning. The U.S. Supreme Court held that the prisoner had not been taken into custody for Miranda purposes, since he was told at the beginning and reminded later that he was free to leave and go back to his cell. Additionally, he was not physically restrained or threatened, was interviewed in a well-lit, average-sized conference room where the door was sometimes left open, and was offered food and water. These "facts are consistent with an environment in which a reasonable person would have felt free to terminate the interview and leave, subject to the ordinary restraints of life behind bars." Howes v. Fields, #10-680, 2012 U.S. Lexis 1077.
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