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The Stolen Valor Act

Autor:   •  November 20, 2018  •  5,253 Words (22 Pages)  •  505 Views

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opposed to the dicta, of this Court’s decisions.” Williams v. Taylor, 529 U. S. 362, 412 (2000). In this case, it is abundantly clear that our precedents do not clearly establish the categorical rule on which the Court of Appeals relied, i.e., that the questioning of a prisoner is always custodial when the prisoner is removed from the general prison population and questioned about events that occurred outside the prison. On the contrary, we have repeatedly declined to adopt any categorical rule Cite as: 565 U. S. ____ (2012) 5 Opinion of the Court with respect to whether the questioning of a prison inmate is custodial. In Illinois v. Perkins, 496 U. S. 292 (1990), where we upheld the admission of un-Mirandized statements elicited from an inmate by an undercover officer masquerading as another inmate, we noted that “[t]he bare fact of custody may not in every instance require a warning even when the suspect is aware that he is speaking to an official, but we do not have occasion to explore that issue here.” Id., at 299 (emphasis added). Instead, we simply “reject[ed] the argument that Miranda warnings are required whenever a suspect is in custody in a technical sense and converses with someone who happens to be a government agent.” Id., at 297. Most recently, in Maryland v. Shatzer, 559 U. S. ___ (2010), we expressly declined to adopt a bright-line rule for determining the applicability of Miranda in prisons. Shatzer considered whether a break in custody ends the presumption of involuntariness established in Edwards v. Arizona, 451 U. S. 477 (1981), and, if so, whether a prisoner’s return to the general prison population after a custodial interrogation constitutes a break in Miranda custody. See 559 U. S., at ___ (slip op., at 3–4). In considering the latter question, we noted first that “[w]e have never decided whether incarceration constitutes custody for Miranda purposes, and have indeed explicitly declined to address the issue.” Id., at ___ (slip op., at 13) (citing Perkins, supra, at 299; emphasis added). The answer to this question, we noted, would “depen[d] upon whether [incarceration] exerts the coercive pressure that Miranda was designed to guard against—the ‘danger of coercion [that] results from the interaction of custody and official interrogation.’” 559 U. S., at ___ (slip op., at 13) (quoting Perkins, supra, at 297). In concluding that our precedents establish a categorical rule, the Court of Appeals placed great weight on the 6 HOWES v. FIELDS Opinion of the Court decision in Mathis, but the Court of Appeals misread the holding in that case. In Mathis, an inmate in a state prison was questioned by an Internal Revenue agent and was subsequently convicted for federal offenses. The Court of Appeals held that Miranda did not apply to this interview for two reasons: A criminal investigation had not been commenced at the time of the interview, and the prisoner was incarcerated for an “unconnected offense.” Mathis v. United States, 376 F. 2d 595, 597 (CA5 1967). This Court rejected both of those grounds for distinguishing Miranda, 391 U. S., at 4, and thus the holding in Mathis is simply that a prisoner who otherwise meets the requirements for Miranda custody is not taken outside the scope of Miranda by either of the two factors on which the Court of Appeals had relied. Mathis did not hold that imprisonment, in and of itself, is enough to constitute Miranda custody.4 Nor, contrary to respondent’s submission, see Brief for Respondent 14, did Oregon v. Mathiason, 429 U. S. 492, 494 (1977) (per curiam), which simply restated in dictum the holding in Mathis. The Court of Appeals purported to find support for its per se rule in Shatzer, relying on our statement that “[n]o one questions that Shatzer was in custody for Miranda purposes” when he was interviewed. 559 U. S., at ___ (slip op., at 13). But this statement means only that the issue of custody was not contested before us. It strains credulity to read the statement as constituting an “unambiguous conclusion” or “finding” by this Court that Shatzer was in custody. 617 F. 3d, at 822. Finally, contrary to respondent’s suggestion, see Brief for Respondent 12–15, Miranda itself did not clearly es- —————— 4 Indeed, it is impossible to tell from either the opinion of this Court or that of the court below whether the prisoner’s interview was routine or whether there were special features that may have created an especially coercive atmosphere. Cite as: 565 U. S. ____ (2012) 7 Opinion of the Court tablish the rule applied by the Court of Appeals. Miranda adopted a “set of prophylactic measures” designed to ward off the “‘inherently compelling pressures’ of custodial interrogation,” Shatzer, supra, at ___ (slip op., at 4) (quoting Miranda, 384 U. S., at 467), but Miranda did not hold that such pressures are always present when a prisoner is taken aside and questioned about events outside the prison walls. Indeed, Miranda did not even establish that police questioning of a suspect at the station house is always custodial. See Mathiason, supra, at 495 (declining to find that Miranda warnings are required “simply because the questioning takes place in the station house, or because the questioned person is one whom the police suspect”). In sum, our decisions do not clearly establish that a prisoner is always in custody for purposes of Miranda whenever a prisoner is isolated from the general prison population and questioned about conduct outside the prison.5 —————— 5The state-court decision applied the traditional context-specific analysis to determine whether the circumstances of respondent’s interrogation gave rise to “the coercive pressure that Miranda was designed to guard against.” Shatzer, 559 U. S., at ___ (slip op., at 13). The court first observed: “That a defendant is in prison for an unrelated offense when being questioned does not, without more, mean that he was in custody for the purpose of determining whether Miranda warnings were required.” App. to Pet. for Cert. 56a (internal quotation marks omitted and emphasis added). In this case, the court noted, the “defendant was unquestionably in custody, but on a matter unrelated to the interrogation.” Ibid. The Sixth Circuit concluded that the state court thereby limited Miranda in a way rejected by Mathis v. United States, 391 U. S. 1 (1968), and “curtail[ed] the warnings to be given persons under interrogation by officers based on the reason why the person is in custody.” Id., at 4–5. We think the better reading is that the state court merely meant to draw a distinction between incarceration and Miranda custody. This reading is supported by the state court’s subsequent consideration of whether the facts of the case were likely to create an atmosphere of coercion. App. to Pet. for Cert. 56a. 8 HOWES v. FIELDS Opinion of

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