Howes v. Fields

Randall Fields (defendant), already imprisoned, was removed from his cell and interrogated for five to seven hours by two sheriff's deputies about unrelated events outside prison; the deputies repeatedly told him he was free to end the questioning and return to his cell, and never gave Miranda warnings. Fields eventually confessed to sexual conduct with a minor. On habeas review, the Sixth Circuit held that interrogating an isolated prisoner about outside-prison events is always custodial as a categorical matter, and the Supreme Court granted review.