In re M.H.

Summary

The Supreme Court of Ohio held that a county child-abuse investigator was not required to provide Miranda warnings before questioning a child because she was neither a law-enforcement officer nor acting under police direction or control. The court also held that the child’s confession did not violate federal due-process protections because it was not causally related to coercive police conduct, and it affirmed the court of appeals’ judgment admitting the statement.

Holdings

1. A child-abuse investigator employed by a county children-services agency is not required to provide Miranda warnings before questioning a suspect when the investigator is neither a law-enforcement officer nor an agent of law enforcement acting under the direction or control of police.
2. Under Colorado v. Connelly, coercive police activity causally related to the confession is a necessary predicate for a federal due-process claim based on an involuntary confession. Because no police officer participated in, directed, or controlled Bradley's interview, the statement was not obtained in violation of federal due process.
3. Even assuming that Bradley's position as a county employee triggered federal due-process protections, M.H. failed to show that his statement was involuntary in the constitutional sense.

Questions Presented

1. Whether a county child-abuse investigator must provide Miranda warnings before questioning a child suspected of committing child abuse when the investigator is neither a law-enforcement officer nor an agent of law enforcement acting under police direction or control.
2. Whether admission of an incriminating statement obtained from a child by a county child-abuse investigator violated the Due Process Clause of the Fourteenth Amendment.
3. Whether the trial court properly suppressed the statement and excluded it under Ohio Evid.R. 403(A).

Disposition

affirmed