After an altercation with the police that led to his arrest, the defendant was seriously injured. An investigating officer approached the defendant while receiving medical attention at the hospital. The defendant admitted that he took the gun from an officer’s holster and pointed it at the police. The defendant also stated “I am not telling you anything until they treat me,” though the officer continued the interview. At no point did the officer ever give the defendant Miranda warnings. The defendant was never charged with the crimes but he filed a suit against the officer for depriving him of his Miranda warnings.
Whether an officer can be held liable for failing to provide Miranda warnings to suspect?
No. The Fifth Amendment’s protections prohibit the government from compelling a suspect from becoming a witness against himself in a criminal case. This did not occur.
The Court stated that as the defendant was “never prosecuted for a crime, let alone compelled to be a witness against himself in a criminal case” a violation of his rights never occurred. A criminal case does not take place until there is “the initiation of legal proceedings.” The Court also stated that “it is enough to say that police questioning does not constitute a ‘case.’” As the defendant was not made to be a witness against himself in a criminal case, no violation of the Constitution occurred.
538 U.S. 760, 123 S. Ct. 1994 (2002)