LOCATION: Rhode Island General Assembly
DOCKET NO.: 00-1028
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Ohio Supreme Court
CITATION: 532 US 17 (2001)
DECIDED: Mar 19, 2001
Facts of the case
Matthew Reiner was charged with involuntary manslaughter in connection with the death of his 2-month-old son Alex. The defense planned to argue that Susan Batt, the family's babysitter, was the culpable party. The trial court granted Batt transactional immunity from prosecution, at the state's request, after she informed the court she intended to assert her Fifth Amendment privilege against self-incrimination. Ultimately, Batt denied any involvement in the death. Reiner was convicted. The Court of Appeals of Ohio reversed. In affirming, the Supreme Court of Ohio held that "Susan Batt's [trial] testimony did not incriminate her because she denied any involvement in the abuse. Thus, she did not have a valid Fifth Amendment privilege." The court noted that the defense's theory of Batt's guilt was not grounds for a grant of immunity, "when the witness continues to deny any self-incriminating conduct." The court also found that the wrongful grant of immunity prejudiced Reiner, because it effectively told the jury that Batt did not cause Alex's injuries.
May a witness who claims no involvement in a crime assert a Fifth Amendment right against self-incrimination?