Aleman v. Village of Hanover Park
662 F.3d 897, 2011 U.S. App. LEXIS 23241, 2011 WL 5865654 (2011)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A confession is unconstitutionally coerced when police use deceptive tactics, such as fabricating evidence, that destroy a suspect's ability to make a rational choice about confessing. Additionally, once a suspect makes a reasonably clear request for counsel during a custodial interrogation, police must cease questioning until counsel is present or the suspect reinitiates communication.
Facts:
- Rick Aleman operated a daycare in his home where 11-month-old Joshua Schrik was in his care.
- On September 9, 2005, after being lethargic and feverish for two days prior, Joshua collapsed at Aleman's home.
- Aleman, alarmed by the collapse, picked up the infant, gently shook him to elicit a response, performed CPR, and called 911.
- At the police station, Officer Micci told Aleman that several doctors had concluded Joshua's injury must have occurred immediately before his collapse, which was a lie.
- This lie induced Aleman to state, "if the only way to cause [the injuries] is to shake that baby, then, when I shook that baby, I hurt that baby."
- Joshua died on September 13; Officer Carlson then lied to the pathologist, claiming Joshua was behaving normally before arriving at Aleman's, which caused the pathologist to wrongly conclude the injury occurred in Aleman's care.
- An investigation by the Department of Children and Family Services later revealed that Joshua's mother had a history of violence, had been seen shaking Joshua, and that medical science supports a possible delay between a head trauma and collapse.
- All charges against Aleman were eventually dismissed more than a year after his arrests.
Procedural Posture:
- Rick Aleman filed a suit under 42 U.S.C. § 1983 in federal district court against several police officers and the Village of Hanover Park.
- The defendants moved for summary judgment on all claims.
- The U.S. District Court (trial court) granted the defendants' motion for summary judgment, dismissing all of Aleman's claims.
- Aleman (appellant) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Seventh Circuit.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does it violate a suspect's constitutional rights for police to continue an interrogation after the suspect has requested counsel and to induce a confession by lying about medical evidence in a way that forecloses any rational conclusion other than guilt?
Opinions:
Majority - Posner, J.
Yes, it violates a suspect's constitutional rights for police to continue an interrogation after a request for counsel and to induce a confession through deceptive lies that destroy the suspect's ability to make a rational choice. The court held that Aleman clearly invoked his right to counsel on two occasions, and under the rule from Edwards v. Arizona, the officers were required to cease all questioning. Instead, they exploited his distraught state and badgered him into signing a waiver, which constitutes a Miranda violation. Furthermore, the court found the confession was unconstitutionally coerced. Unlike permissible minor trickery, Officer Micci’s lie about the medical evidence was a falsehood that destroyed the information Aleman required for a rational choice. By falsely representing settled medical opinion, the police placed Aleman in a logical vise where he was compelled to conclude he must be guilty, rendering the resulting confession worthless as evidence.
Analysis:
This decision clarifies the boundary between permissible police trickery and unconstitutional coercion during an interrogation. It establishes that while police may use some deception, they cannot fabricate evidence or expert opinions to such a degree that it eliminates a suspect's capacity for rational choice. The ruling creates a strong precedent against using false scientific or medical claims to secure confessions. By distinguishing this type of deception from minor frauds, the court protects suspects, particularly those without specialized knowledge, from being logically compelled into making false admissions of guilt.
Unlock the full brief for Aleman v. Village of Hanover Park