Chavez v. Martinez
United States Supreme Court
538 U.S. 760 (2003)
Officers shot Oliviero Martinez (plaintiff) multiple times after he grabbed one officer's gun during a confrontation. While Martinez underwent emergency treatment at the hospital, unbelieving he would survive, patrol supervisor Ben Chavez (defendant) interrogated him without giving Miranda warnings, and Martinez confessed. He was never charged with a crime. Martinez sued Chavez under 42 U.S.C. § 1983, claiming violations of his Fifth Amendment self-incrimination right and his Fourteenth Amendment due-process right against coercive interrogation; Chavez sought summary judgment, which the district court denied and the court of appeals affirmed on interlocutory appeal.
(1) Whether an officer's coercive interrogation of a suspect violates the suspect's Fifth Amendment privilege against self-incrimination if the resulting statement is never used in a criminal case. (2) Whether such coercive interrogation may violate substantive due process even if the statement is never used in a criminal case.