Ohio v. Reiner - 532 U.S. 17, 121 S. Ct. 1252 (2001)

Rule:

The privilege against self-incrimination extends not only to answers that would in themselves support a conviction, but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant. It need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result. 

Facts:

A father whose child had died of "shaken baby" syndrome was tried in the Lucas County Court of Common Pleas, an Ohio trial court, for involuntary manslaughter. The father's defense was that the child's babysitter was guilty. The babysitter informed the court in advance of testifying that she intended to assert her privilege against self-incrimination under the Federal Constitution's Fifth Amendment. The trial court granted her transactional immunity from prosecution and the witness testified that she had had no involvement with the death of the child. The father was found guilty of involuntary manslaughter at the trial. The conviction was reversed on other grounds in the Court of Appeals of Ohio. Subsequently, the Supreme Court of Ohio affirmed the reversal of the father's manslaughter conviction on the alternative grounds that the witness had no valid Fifth Amendment privilege and that the trial court's grant of immunity was therefore invalid.

Issue:

Did the babysitter who denied all culpability in manslaughter trial have a valid privilege against self-incrimination under Federal Constitution's Fifth Amendment, where she had reasonable cause to apprehend danger from her answers if questioned at trial?

Answer:

Yes

Conclusion:

The United States Supreme Court held that, while the self-incrimination privilege's protection only extended to witnesses who had reasonable cause to apprehend danger from a direct answer, the babysitter's expression of innocence did not by itself eliminate the babysitter's privilege. It was reasonable for the babysitter to fear that answers to possible questions might tend to incriminate her, despite her asserted innocence. Thus the grant of immunity was neither wrongful nor prejudicial to respondent.