Saturday, November 2, 2013

Chavez v. Martinez case brief

Chavez v. Martinez case brief summary
538 U.S. 760 (2003)

Respondent sued petitioner police officer under 42 U.S.C.S. § 1983 alleging that the officer coerced a confession from respondent in violation of respondent's constitutional privilege against self-incrimination and his right to due process. Upon the grant of a writ of certiorari, the officer appealed the judgment of the United States Court of Appeals for the Ninth Circuit which denied the officer's claim of qualified immunity.

Respondent asserted that the officer engaged in coercive interrogation tactics while respondent was undergoing medical treatment for potentially fatal injuries from being shot by another officer. Respondent contended that the interrogation was unconstitutional, even though respondent was never charged with a crime and his statements were never used against him. "


  • The United States Supreme Court held that the officer was entitled to qualified immunity since the officer committed no violation of respondent's constitutional rights. 
  • A plurality of the court found that respondent was not compelled to be a witness against himself, and the circumstances warranted the intense questioning to preserve respondent's version of events. 
  • A majority of the Court agreed, however, that additional consideration was necessary to address whether respondent could pursue a claim of liability for a substantive due process violation.


The judgment denying the officer's claim of qualified immunity was reversed, and the case was remanded to address whether respondent could pursue a claim of liability for a substantive due process violation, and the scope and merits of any such claim.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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