finding an inmate’s incriminating statement made at a prison disciplinary hearing without the benefit of Miranda warnings inadmissible at trial
How later courts described this case
- finding an inmate’s incriminating statement made at a prison disciplinary hearing without the benefit of Miranda warnings inadmissible at trial
- prohibiting the use of statements at trial that were obtained when a prison warden questioned an inmate without giving proper Miranda warnings
- statements made to a prison warden
Written by the judges who cited it.
The opinion
PER CURIAM:
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.