General Introduction to the Case
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The case involves Carol Howes, who is a Warden of the Lakeland Correctional Facility in Michigan as the petitioner. Randall Fields who is a prisoner at the Lakeland Correctional Facility is the respondent. Randall Fields is sentenced to imprisonment for ten to fifteen years. He is serving the sentence under state convictions for criminal sexual conduct of the third degree.
According to the petition side of the case, two sheriff’s deputies removed Randall Fields from his cell without advice on his Miranda rights. However, Fields was informed that he was at liberty to leave if he was not willing to continue with the interrogation. Nonetheless, the respondent did not leave or ask to be escorted back to the cell. The petitioner argues that a bright-line Miranda rule that was applied in this case gives convicted criminals more rights even than ordinary citizens (American Bar Association 12). The petitioner further asserts that the Court should endorse Miranda context-specific test especially where prisoners are involved and thus should revert the new bright-line approach of the Sixth Circuit.
According to the respondent side of the case, Fields’ Miranda rights were violated since he was not duly instructed of these rights before the interrogation and removal from the jail as is legally expected. Although he was informed of his liberty to leave if he was not willing to continue with the interrogation, there was actually no one to escort him back to the cell since he was not familiar with the building.
Randall Fields had no alternative but to sit and continue with the interrogation since there was no one to escort him back to the cell. Therefore, whereas he was at liberty to leave, this was not absolutely guaranteed. This is contrary to the provisions of the Fifth Amendment law that guarantees the application of the bright-line test in relation to cases involving custodial interrogations (American Bar Association 18). The Supreme Court law also requires that Miranda rights be given to an inmate removed from prison population for interrogation outside the prison and where the officers involved are unaffiliated with the prison (American Bar Association 18).
The case requires the Supreme Court to determine the applicability of Miranda rights rules and whether or not Fields was entitled to these rights during his interrogation away from the general prison population. It also involves determination of whether or not the Fifth Amendment law absolutely applies where custodial interrogations are involved (American Bar Association 12). The Supreme Court is thus to determine whether, in line with the Fifth Amendment law and the bright-line Miranda principle, Fields’ rights were actually violated during the interrogation away from the prison population.
Ideological issues in the Case
The liberal side of this case would support Fields on grounds that he was not informed of his Miranda rights even as he was being removed from the general prison population for interrogation in the conference room in unusually odd hour. Although he was informed that he had the option of leaving back to the jail, one of the deputies admittedly testified that the defendant was not escorted back to the cell (Dominguez 2011). The liberal side would thus support the respondent and base their decision on the grounds that his rights as provided for in the Fifth Amendment law and the bright-line test approach to Miranda warnings were violated.
The conservative side would favor Carol Howes, the petitioner by resorting to the provisions of Mathis (American Bar Association 10). The conservatives would endorse Miranda context-specific test approach in this case. Hemmes et al (550) posits that this provision holds that Miranda rights are applicable but do not expressly establish that such individuals in custody be automatically entitled to Miranda warnings every time they are to be interrogated away from the general prison population (Brody and Acker 245).
Supreme Court’s Possible Ruling
Generally, the Court would adopt a liberal decision in its ruling. This decision is influenced by the provision of the Fifth Amendment and the application of the bright-line test approach to Miranda rights. Further, the Supreme Court law provides that Miranda rights be given to any inmate removed from prison population for interrogation on occurrences outside the prison and where the officers involved are unaffiliated with the prison (American Bar Association 18). This right was violated by the petitioner. This explains why the decision is likely to be liberal and in favor of the respondent.
Personal Opinion about the Case
In the petition case involving Carol Howes and Randall Fields, I would rule in favor of the respondent. This is because the Sixth Circuit’s Mathis provides that Miranda warnings must be issued whenever a law enforcement officer removes any inmate from the general population for any custodial interrogations (Dominguez 2011). Fields was not entitled to the Miranda rights at the time of his removal from the jail.
Precedent and Impact of the Case
The precedent in this case is founded on the general provisions for Miranda rights. In the case of Oregon and Mathiason, 429 U.S. 494 (1977), the court considering Mathis, decided that Miranda principle is absolutely applicable based on the bright-line approach in the contexts where interrogation of a prisoner takes place in a setting away from the prison population (American Bar Association 21). In Oregon versus Mathiason, the Court decisively stated that Miranda rights are very applicable where there is restriction on a prisoner’s freedom and where the interrogation is coercive. This was the same in the case of Fields versus Howes. In this respect, the role of stare decisis will be very critical in the Supreme Court’s decision in this case.
The Court will also rely on the results of the precedent case involving Rhodes Island versus Innis, 446 U.S. 291, 301 (1980). In this case, the Court was to decide on a matter where there was dispute between application of bright-line test principle and the contextual test approach to Miranda provisions (Hemmes et al 550). In this case the Court decided that the coerciveness of the interrogation environment is a separate question from the matter involving custody. Therefore, where the prisoner is already in custody, the bright-line approach to Miranda is applicable in line with the provisions of the Fifth Amendment law that the Supreme Court refers to in cases of a similar nature (Brody and Acker 245-246).
Considering the precedent and evaluating the impact of this case, United States versus Menzer of 1994 could be used as a reference. In this case, the officers that were doing the interrogations worked hard to ensure that the interrogations were as non-coercive as possible. The inmate was also given the option to decide whether or not he wanted to meet the officers for interrogations (Brody and Acker 245-246). This is why the Court ruled in favor of the petitioner. On the contrary Fields was not granted this right. His interrogation was openly coercive. This explains why the Supreme Court must not go on the contrary in consideration of the precedent cases and the stare decisis.
The precedent cases and the role of stare decisis would be very critical in determining the outcome of this case. This is because in principle, the Supreme Court does not contradict itself. The provision of Sixth Circuit that holds that routine questioning does not require advice on the rights would thus be ignored in this case (American Bar Association 32). Instead, the Court would refer to Mathis and the Fifth Amendment law as the controlling precedent in this case.
The outcome of this case would be very critical especially in terms of setting precedence for the future cases involving interrogation of prisoners and where the Miranda warning provisions are involved. Besides, it will be very significant especially considering the fact that bright-line and Miranda context-specific test approaches have been crowded by differences in interpretation in the lower Courts. The decision of the Supreme Court in Fields versus Howes would thus be used as a referent case to guide future rulings in cases involving rights of prisoners that are being interrogated away from the general prison population.
Relevance of the Case to Class Learning Context
The case is very relevant to the course content as it involves determination of violation of Miranda rights or the absence of the same. It is further interesting to explore how this connects with the provisions of the Fifth Amendment law that guides cases involving custodial interrogations. The Fifth Amendment law reinforces the bright-line test and Miranda principles as it relates to custodial interrogations. Therefore, proper considerations must be made so as to help a person understand and exploit all the privileges that the case settings provide. Fields was not guaranteed this right and privilege during his interrogation.
The Fifth Amendment law also provides that the defendant in a custodial case be made aware of the right to remain silent in the interrogation process. This is quite contextual in this case especially considering that Randall Fields was not absolutely given this right. This is despite the fact the Fifth Amendment and the provision of Miranda warning and rights safeguards his rights since he is in legal custody until he has fully served his ten to fifteen year sentence.
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