On January 24, 2011, the U.S. Supreme Court granted certiorari in Howes v. Fields that raises the issue of whether an individual incarcerated in prison is "in custody" for purposes of Miranda where police interogate said person on matters unrelated to his incarceration.
Certiorari Petition in Howes v Fields
Opposition to Petition for Cert Howes v Fields
Petitioners' Reply Brief on Petition for Writ of Certiorari in Howes v Fields