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Howes v. Fields
Supreme Court of the United States (2012) | 182 L. Ed. 2d 17; 132 S. Ct. 1181; 565 U.S. 499; 2012 U.S. LEXIS 1077; 2012 WL 538280
TL;DR: A prisoner was questioned for hours about an outside crime without Miranda warnings. The Supreme Court held he was not "in custody" because imprisonment alone is not custody for Miranda purposes, and he was told he could end the interview and return to his cell.
Legal Significance: Rejects a categorical rule for prison interrogations, establishing that "custody" for Miranda purposes requires a totality-of-the-circumstances analysis. Imprisonment itself is not determinative; the focus is on whether the interrogation environment creates coercive pressures akin to a station house arrest.