Supreme court cases 2002-2003 term

FBI Law Enforcement Bulletin,The, April, 2004 by Michael J. Bulzomi

Each year the United States Supreme Court is asked to review a multitude of cases covering a variety of legal topics. The 2002-2003 Supreme Court session was no different. The justices decided several cases of interest to law enforcement officers and management. The Court decided two cases involving confessions. Three Americans with disabilities cases were decided: one dealing with the definition of a major life function; one concerning reasonable accommodation; and one dealing with a direct threat to a disabled person's own health. A First Amendment speech case was decided, as well as a Title VII case involving the required proof in a mixed-motive sexual discrimination case.

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Chavez v. Martinez, 123 S. Ct. 1994 (May 27, 2003)

The U.S. Supreme Court decided that a police officer's failure to give Miranda warnings, coupled with coercive questioning of a defendant, did not violate the defendant's privilege against self-incrimination under the Fifth Amendment. The Court stated that the privilege is not violated until the government tries to use the offending statement against a defendant in a criminal case. However, the Court did not decide whether the officer's actions in this case violated the due process clause of the Fourteenth Amendment.

Martinez was questioned by Sergeant Chavez while in an emergency room, suffering from gunshot wounds inflicted by another police officer. Martinez was in severe pain and believed he was about to die when he admitted using heroin and stealing a police officer's gun. Chavez never advised Martinez of his Miranda rights. Martinez was never charged with any crime.

Martinez later filed a Title 42, Section 1983, U.S. Code lawsuit against Chavez for violating his Fifth Amendment privilege against self-incrimination and his Fourteenth Amendment substantive due process right to be free from coercive questioning. The district court and the U.S. Circuit Court of Appeals for the Ninth Circuit held that Chavez was not entitled to qualified immunity because he obtained the statements coercively. The fact that the government never tried to use the statements in a criminal trial was irrelevant to these courts. The Supreme Court reversed.

The Supreme Court held that compulsive questioning alone, unrelated to a criminal case, does not violate the Fifth Amendment self-incrimination clause. The phrase "criminal case" in the self-incrimination clause, at the very least requires initiation of legal proceedings and does not encompass the entire criminal investigatory process, including police interrogations. Statements compelled by police interrogation may not be used against a defendant in a criminal case. Martinez was never made to be a "witness" against himself because his statements never were admitted as testimony against him in a criminal case.

The Court also concluded that Chavez's failure to read Miranda warnings to Martinez did not violate Martinez's constitutional rights. The majority agreed that a simple Miranda violation was not a violation of a "core" Fifth Amendment right and, therefore, could not support a Section 1983 civil action, requiring an actual violation of a constitutional right.

The Court did not resolve the question of whether or not Chavez's questioning violated Martinez's substantive due process rights under the Fourteenth Amendment. That issue was remanded to the Ninth Circuit for additional proceedings. In an opinion dated July 30, 2003, the Ninth Circuit ruled that Chavez's coercive interrogation of Martinez violated his clearly established due process rights under the Fourteenth Amendment.

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Kaupp v. Texas, 123 S. Ct. 1843 (May 5, 2003) (per curiam)

In this case, a 17-year-old murder suspect was awakened by at least three officers at 3 a.m. One officer told the boy, "we need to go and talk," to which the boy responded, "Okay." The boy was led away in handeuffs, wearing only his underwear, taken to the scene of the crime where the victim's body had just been recovered, and then taken to the police station. All parties agree that the police, at this point, did not have probable cause to arrest the young man. At the station, the youth was given his Miranda rights. After a brief interrogation, he confessed to some involvement in the murder. He unsuccessfully challenged the use of his confession, alleging that his unlawful arrest tainted his subsequent confession. The boy was given a 55-year sentence.

On appeal, Texas courts affirmed the conviction. They reasoned that the boy's response of "Okay" indicated consent, that his failure to protest was a waiver of rights, and that his transport to the station in handcuffs was simply routine.

The Court vacated the conviction. It concluded that a 17-year-old boy being awakened late at night, taken to the police station in handcuffs in his underwear, and interrogated, is indistinguishable from a traditional arrest. Because the boy was arrested without probable cause, his subsequent confession must be suppressed absent evidence of intervening events sufficient to purge the taint of the unlawful seizure. In the Court's view, the fact that Miranda rights were given was not sufficient to purge the taint in this circumstance.