## Facts

- Oxnard, California police stopped Oliverio Martinez during a narcotics investigation; a struggle occurred as officers tried to handcuff him.
- An officer shot Martinez multiple times, leaving him severely injured and later partially paralyzed and blind.
- Police supervisor Ben Chavez arrived as paramedics treated Martinez, accompanied him in an ambulance and at the hospital, and questioned him intermittently for about 45 minutes.
- Martinez, while receiving emergency care and stating he was dying, answered questions and made incriminating statements, including drug use and grabbing an officer’s gun.
- Chavez did not provide Miranda warnings during the questioning.
- Martinez was never charged with a crime, and his statements were never used against him in any criminal proceeding.
- Martinez sued under 42 U.S.C. § 1983, alleging violations of (1) the Fifth Amendment Self-Incrimination Clause and (2) Fourteenth Amendment substantive due process based on coercive interrogation.

## Issues

1. Whether coercive, unwarned custodial questioning violates the Fifth Amendment Self-Incrimination Clause actionable under § 1983 when the statements are never used in a criminal case.
2. Whether the interrogation tactics, given Martinez’s medical condition and circumstances, could violate the Fourteenth Amendment’s substantive due process protections.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- A majority agreed there was no completed Fifth Amendment Self-Incrimination Clause violation because Martinez’s statements were not used against him in a criminal case.
- The Court rejected the Ninth Circuit’s rule that coercive questioning alone violates the Self-Incrimination Clause for § 1983 damages purposes.
- The Court remanded for further consideration of Martinez’s substantive due process claim based on the alleged coercive questioning and circumstances.
- The Court’s opinions were fragmented, but the judgment denied Fifth Amendment § 1983 liability on the theory accepted by the Ninth Circuit while leaving due process issues for further proceedings.

## Legal Principles

- The Self-Incrimination Clause is violated by the use of compelled statements against a person in a “criminal case”; coercive police questioning, without such use, does not itself complete the constitutional violation.
- A failure to provide Miranda warnings, without subsequent use of the statements in a criminal proceeding, does not by itself support damages under § 1983 on a Fifth Amendment theory.
- Qualified immunity analysis turns on whether the officer violated a constitutional right and whether that right was clearly established.
- Egregious interrogation conduct may still be actionable, if at all, under the Fourteenth Amendment’s substantive due process standard; evaluation of that claim depends on the facts and was not resolved on the merits in this decision.

## Conclusion

The Court held that Martinez could not recover § 1983 damages for a Fifth Amendment Self-Incrimination Clause violation because his statements were never used in a criminal case, and it remanded for lower courts to assess whether the alleged coercive interrogation could violate substantive due process.


Chavez v. Martinez, 538 U.S. 760 (2003)