At page 455 Interpreting prison confinement as custody for legal purposes4 citing cases
- Shatzer v. State, 954 A.2d 1118 (Md. 2008).published The Majority Opinion turned to a state statutory interpretation case for this point of law only. [9] Mathis v. United States, 391 U.S. 1 , 88 S.Ct. 1503 , 20 L.Ed.2d 381 (1968). [10] The Majority Opinion here also relies upon United States…
- People v. Wyngaard, 575 N.W.2d 48 (Mich. Ct. App. 1998).publishedAvant v. Clifford, 67 N.J. 496, 538-540 , 341 A.2d 629 (1975); Carter v. McGinnis, 351 F.Supp. 787, 794 (W.D.N.Y., 1972); People v. Stamus, 902 P.2d 936, 938 (Colo.App., 1995); Grant v. State, 154 Ga.App. 758 , 270 S.E.2d 42 (1980); Pruitt…
- Whitfield v. State, 411 A.2d 415 (Md. 1980).publishedWhile a few courts have been willing to interpret Mathis in this broad fashion — that prison confinement equals custody — see United States v. Redfield, 402 F.2d 454, 455 (4th Cir. 1968) (per curiam); Blyden v. Hogan, 320 F. Supp. 513, 519…
- Makanani v. Wagutsuma, No. 1:19-cv-00546, 2019 WL 7373030 (D. Haw. Dec. 31, 2019).See United States v. Redfield, 402 F.2d 454, 455 (4th Cir. 1968) (per curiam) (finding an inmate’s incriminating statement made at a prison disciplinary hearing without the benefit of Miranda warnings inadmissible at trial); see also Mathi…
Other citing cases
- Bostic v. Ebbert, No. 3:19-cv-01279 (M.D. Pa. July 28, 2020).
- People v. Stamus, 902 P.2d 936 (Colo. Ct. App. 1995).published
- Whitfield v. State, 400 A.2d 772 (Md. Ct. Spec. App. 1979).published
v.
Roland Bobby REDFIELD, Appellant
Roland B. Redfield was convicted of obtaining marijuana without paying a transfer tax in violation of 26 U.S.C. § 4744(a) (1) while he was an inmate at Lorton Reformatory. The district court allowed a warden to testify that when Redfield was questioned at a prison disciplinary hearing he admitted ownership of the marijuana. In this appeal we do not pass upon the disciplinary board’s use of Redfield’s admission. Our inquiry is limited to the admissibility of the incriminating statement in Redfield’s criminal trial. Before he was questioned, Redfield was not cautioned of his right to be silent and his right to counsel, as prescribed by Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). Mathis v. United States, 391 U.S. 1, 88 S.Ct 1503, 20 L.Ed.2d 381 (1968), decided after Redfield’s trial, applied Miranda to the questioning of a person in prison for a crime that was not connected with the tax delinquencies under investigation. The role of Redfield’s interrogator did not differ significantly from that of the internal revenue agent in Mathis. In both instances the immediate objective of the officials was not to obtain evidence for use in criminal trials. Only later did the government decide to use the defendant’s self-incriminatory answers in prosecutions under the revenue laws. For these reasons we believe Mathis requires the exclusion of Redfield’s admission. Red-field’s other contentions are without merit.
The judgment is vacated, and the case is remanded for a new trial.