In Howes v. Fields (2012) U.S. 132 S.Ct. 1181, while the defendant was serving a sentence in a Michigan jail, he was escorted to a conference room where he was questioned by two sheriff deputies about an incident that occurred prior to his imprisonment. (Howes v. Fields, supra, U.S. at p. 132 S.Ct. at p. 1185.) At the beginning of the questioning, Fields was told he was free to leave and return to his cell. Later, he was again told he was free to leave. He was not restrained by handcuffs or manacles, and the door to the room was open at times during the questioning. (Id. at p. 132 S.Ct. at p. 1186.) At no time was Fields advised of his Miranda rights or informed he did not have to speak to the officers. (Ibid.) Fields contended the statements he made during the questioning were obtained in violation of Miranda. (Ibid.) The court concluded "'custody'" is a term of art in Miranda jurisprudence and is meant to designate circumstances "that are thought generally to present a serious danger of coercion." (Howes v. Fields, supra, U.S. at p. 132 S.Ct. at p. 1189.) A determination of custody is but the first step in deciding whether, given the objective circumstances of the questioning, "a 'reasonable person would have felt he or she was not at liberty to terminate the interrogation and leave.' " (Ibid.) The court went on to state, "Not all restraints on freedom of movement amount to custody for purposes of Miranda." (Id. at p. 132 S.Ct. at p. 1189.) In the context of a sentenced prisoner questioned about an offense that occurred outside prison, the court found at least three reasons why the "standard conditions of confinement and associated restrictions on freedom will not necessarily implicate the same interests that the Miranda Court sought to protect when it afforded safeguards to persons subjected to custodial interrogation." (Howes v. Fields, supra, U.S. at p. 132 S.Ct. at p. 1191.) First, the person already serving a sentence is not presented with the same shock that often accompanies an initial arrest just prior to questioning. (Id. at p. 132 S.Ct. at p. 1190.) Second, a prisoner is unlikely to believe the questioning officer has the authority to promptly release him or her. Thus, the defendant will be less likely to talk to the officer with the hope of being immediately released. (Id. at p. 132 S.Ct. at p. 1191.) Third, a sentenced prisoner will know the questioning officer lacks the authority to shorten his or her already imposed sentence. (Ibid.) As a result, the court concluded that "when a prisoner is questioned, the determination of custody should focus on all of the features of the interrogation. These include the language that is used in summoning the prisoner to the interview and the manner in which the interview is conducted. An inmate who is removed from the general prison population for questioning and is 'thereafter . . . subjected to treatment' in connection with the interrogation 'that renders him in "in custody" for practical purposes . . . will be entitled to the full panoply of protections prescribed by Miranda.' " (Howes v. Fields, supra, U.S. at p. 132 S.Ct. at p. 1192.) The court considered the facts suggesting Fields was in custody for purposes of requiring a Miranda advisement: he was summoned to the conference room for questioning, he was not advised he did not have to speak with the deputies, the deputies were armed, the questioning lasted between five and seven hours, and once a deputy used a sharp tone of voice with Fields (Howes v. Fields, supra, U.S. at p. 132 S.Ct. at pp. 1192-1193.) The court also chronicled those facts militating toward Fields not being considered in custody for purposes of requiring an advisement -- Fields had been advised at the beginning he could leave and go back to his cell whenever he wanted, he was not physically restrained, during the questioning he was again told he could leave, he was not threatened, the questioning took place in a well-lit conference room, he was not "uncomfortable," he was offered food and water, and the door to the room was left open at times during the questioning. (Id. at p. 132 S.Ct. at p. 1193.) The court concluded, on balance, the evidence demonstrated Fields was not in custody for purposes of requiring advisement per Miranda. "Taking into account all of the circumstances of the questioning--including especially the undisputed fact that respondent was told that he was free to end the questioning and to return to his cell--we hold that respondent was not in custody within the meaning of Miranda. (Id. at p. 132 S.Ct at p. 1194.)