In the case of Carol Howes, Warden v. Randall Lee Fields (2011), the US Supreme Court ruled that an inmate's interaction with prison officials did not necessarily constitute a custodial situation requiring Miranda warnings. The case revolved around Fields, who was serving a sentence in Michigan and was questioned by deputies about criminal activities outside of prison without being read his Miranda rights. He confessed to these crimes during this questioning and later sought to suppress his confession on grounds that he had not been advised of his right against self-incrimination or right to counsel as required by Miranda v. Arizona (1966). However, the Supreme Court held that because Fields was told he could leave at any time and return to his cell, he wasn't "in custody" for purposes of receiving such warnings - despite already being incarcerated.

In the dissenting opinion for the case of Carol Howes, Warden v. Randall Lee Fields (2011), Justice Ginsburg argued that Fields was in custody and should have been read his Miranda rights before being questioned by deputies about allegations made against him. She contended that a reasonable person would not feel free to terminate an interrogation while serving a prison sentence, especially when taken from their cell late at night and interrogated without any indication of how long it would last or whether they could return to their cell if they wished. The majority's decision failed to consider these factors which are critical in determining whether someone is 'in custody' for Miranda purposes. Therefore, she disagreed with the ruling that Fields was not entitled to be advised of his constitutional rights prior to questioning.