AllBestEssays.com - All Best Essays, Term Papers and Book Report
Search

The Stolen Valor Act

Essay by   •  December 6, 2017  •  Research Paper  •  5,246 Words (21 Pages)  •  496 Views

Essay Preview: The Stolen Valor Act

Report this essay
Page 1 of 21

Case Study: The Stolen Valor Act

Supreme court of the United States, Petitioner v. Randall Lee Fields ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT [February 21, 2012] JUSTICE ALITO delivered the opinion of the Court. The United States Court of Appeals for the Sixth Circuit held that our precedents clearly establish that a prisoner is in custody within the meaning of Miranda v. Arizona, 384 U. S. 436 (1966), if the prisoner is taken aside and questioned about events that occurred outside the prison walls. Our decisions, however, do not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provides a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U. S. C. §2254(d)(1). Indeed, the rule applied by the court below does not represent a correct interpretation of our Miranda case law. We therefore reverse. I While serving a sentence in a Michigan jail, Randall Fields was escorted by a corrections officer to a conference room where two sheriff’s deputies questioned him about allegations that, before he came to prison, he had engaged in sexual conduct with a 12-year-old boy. In order to get to the conference room, Fields had to go down one floor and 2 HOWES v. FIELDS Opinion of the Court pass through a locked door that separated two sections of the facility. See App. to Pet. for Cert. 66a, 69a. Fields arrived at the conference room between 7 p.m. and 9 p.m.1 and was questioned for between five and seven hours.2 At the beginning of the interview, Fields was told that he was free to leave and return to his cell. See id., at 70a. Later, he was again told that he could leave whenever he wanted. See id., at 90a. The two interviewing deputies were armed during the interview, but Fields remained free of handcuffs and other restraints. The door to the conference room was sometimes open and sometimes shut. See id., at 70a–75a. About halfway through the interview, after Fields had been confronted with the allegations of abuse, he became agitated and began to yell. See id., at 80a, 125a. Fields testified that one of the deputies, using an expletive, told him to sit down and said that “if [he] didn’t want to cooperate, [he] could leave.” Id., at 89a; see also id., at 70a– 71a. Fields eventually confessed to engaging in sex acts with the boy. According to Fields’ testimony at a suppression hearing, he said several times during the interview that he no longer wanted to talk to the deputies, but he did not ask to go back to his cell prior to the end of the interview. See id., at 92a–93a. When he was eventually ready to leave, he had to wait —————— 1Fields testified that he left his cell around 8 p.m. and that the interview began around 8:30 p.m. App. to Pet. for Cert. 77a. Both the Michigan Court of Appeals and the Sixth Circuit stated that the interview began between 7 p.m. and 9 p.m. See id., at 4a, 54a. 2The Court of Appeals stated that the interview lasted for approximately seven hours, see id., at 4a, a figure that appears to be based on the testimony of one of the interviewing deputies, see id., at 123a. Fields put the number of hours between five and five and a half, saying the interview began around 8:30 p.m. and continued until 1:30 a.m. or 2 a.m. See id., at 77a. The Michigan Court of Appeals stated that the interview ended around midnight, which would put the length of the interview at between three and five hours. Cite as: 565 U. S. ____ (2012) 3 Opinion of the Court an additional 20 minutes or so because a corrections officer had to be summoned to escort him back to his cell, and he did not return to his cell until well after the hour when he generally retired.3 At no time was Fields given Miranda warnings or advised that he did not have to speak with the deputies. The State of Michigan charged Fields with criminal sexual conduct. Relying on Miranda, Fields moved to suppress his confession, but the trial court denied his motion. Over the renewed objection of defense counsel, one of the interviewing deputies testified at trial about Fields’ admissions. The jury convicted Fields of two counts of third-degree criminal sexual conduct, and the judge sentenced him to a term of 10 to 15 years of imprisonment. On direct appeal, the Michigan Court of Appeals affirmed, rejecting Fields’ contention that his statements should have been suppressed because he was subjected to custodial interrogation without a Miranda warning. The court ruled that Fields had not been in custody for purposes of Miranda during the interview, so no Miranda warnings were required. The court emphasized that Fields was told that he was free to leave and return to his cell but that he never asked to do so. The Michigan Supreme Court denied discretionary review. Fields then filed a petition for a writ of habeas corpus in Federal District Court, and the court granted relief. The Sixth Circuit affirmed, holding that the interview in the conference room was a “custodial interrogation” within the meaning of Miranda because isolation from the general prison population combined with questioning about conduct occurring outside the prison makes any such interrogation custodial per se. The Court of Appeals reasoned that this Court clearly established in Mathis v. United —————— 3Fields testified that his normal bedtime was 10:30 p.m. or 11 p.m. See id., at 78a. 4 HOWES v. FIELDS Opinion of the Court States, 391 U. S. 1 (1968), that “Miranda warnings must be administered when law enforcement officers remove an inmate from the general prison population and interrogate him regarding criminal conduct that took place outside the jail or prison.” 617 F. 3d 813, 820 (CA6 2010); see also id., at 818 (“The central holding of Mathis is 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 selfincrimination, about conduct occurring outside of the prison”). Because Fields was isolated from the general prison population and interrogated about conduct occurring in the outside world, the Court of Appeals found that the state court’s decision was contrary to clearly established federal law as determined by this Court in Mathis. 617 F. 3d, at 823. We granted certiorari. 562 U. S. ___ (2011). II Under AEDPA, a federal court may grant a state prisoner’s application for a writ of habeas corpus if the statecourt adjudication pursuant to which the prisoner is held “resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” 28 U. S. C. §2254(d)(1). In this context, “clearly established law” signifies “the holdings, as

...

...

Download as:   txt (30.8 Kb)   pdf (170.4 Kb)   docx (20.1 Kb)  
Continue for 20 more pages »
Only available on AllBestEssays.com
Citation Generator

(2017, 12). The Stolen Valor Act. AllBestEssays.com. Retrieved 12, 2017, from https://www.allbestessays.com/essay/The-Stolen-Valor-Act/68455.html

"The Stolen Valor Act" AllBestEssays.com. 12 2017. 2017. 12 2017 <https://www.allbestessays.com/essay/The-Stolen-Valor-Act/68455.html>.

"The Stolen Valor Act." AllBestEssays.com. AllBestEssays.com, 12 2017. Web. 12 2017. <https://www.allbestessays.com/essay/The-Stolen-Valor-Act/68455.html>.

"The Stolen Valor Act." AllBestEssays.com. 12, 2017. Accessed 12, 2017. https://www.allbestessays.com/essay/The-Stolen-Valor-Act/68455.html.