Legal question re: fifth amendment rights and laws that require you to speak

Arising from this post in the pit:

Short version: A mechanic working on a customer’s car in a church parking lot got arrested, more or less, for refusing to surrender his ID. He filed suit against the arresting officers; his suit was initially dismissed due to qualified immunity - and then reinstated by another judge who found that the officer’s conduct was so far beyond the pale that qualified immunity did not apply.

Which is all well and good, but my question is about the original Alabama stop-and-identify law under which the officers claimed their justification. The law says this:

A sheriff or other officer acting as sheriff, his deputy or any constable, acting within their respective counties, any marshal, deputy marshal or policeman of any incorporated city or town within the limits of the county or any highway patrolman or state trooper may stop any person abroad in a public place whom he reasonably suspects is committing, has committed or is about to commit a felony or other public offense and may demand of him his name, address and an explanation of his actions.

I assume there’s a corresponding section in the law somewhere that says a person is in violation of ??? when they refuse to provide name, address, and an explanation of actions when demanded by an officer in accordance with 15-5-30. My understanding is that police are within their authority to compel you to identify yourself when you are reasonably suspected of a crime. But what’s the deal with requiring a detainee to explain their actions? Isn’t this a pretty blatant violation of the fifth amendment?

The law is worded strangely. It says an officer “…may demand of him his name, address and an explanation of his actions.”

This does not need to be stated in a law. That’s because any officer in any state can ask you any question at any time. It doesn’t mean you have to answer, of course.

In (I believe) all states in the U.S., an officer can detain a person if they have a reasonable articulable suspicion (RAS) the person:

  1. Has committed a crime.
  2. Is committing a crime.
  3. Is about to commit a crime.

Furthermore, in most states, if an officer lawfully detains someone, the person must provide their name, address, and/or date of birth if asked. Failure to provide this information is a crime in-and-of-itself, even if the person is not committing a crime.

The key word in the previous paragraph is lawfully. Quite frequently, officers will detain someone when they do not have RAS the person has, is, or is about to commit a crime.

In this case the officers f’d-up. Let’s review it.

Roland Edger was in a church parking lot, working on his customer’s car. His customer’s name is Kajal Ghosh, and she works at the church. A security guard saw him and called the police. The police show up and ask him what he’s doing. (I am assuming Mr. Edger is lawfully detained at this time, even though it wasn’t verbally stated by the officers.) He gives a perfectly reasonable answer: “I am working on my customer’s car.” It’s also obvious that he is indeed working on the car, and not attempting to break in to it or steal it. The only reasonable suspicion might be catalytic converter theft, I suppose.

At any rate, Mr. Edger provided the officers with a perfectly reasonable explanation of his actions, which he didn’t even have to do. He didn’t attempt to run away, and even continued to work on the car. Furthermore, he offered to provide the officers Ms. Ghosh’s phone number to verify what’s going on. The officers should have contacted her, and then the investigation should have stopped right there, and the detainment should have ended.

Instead, the officers escalated the situation and failed to perform a proper investigation. A proper investigation would have included running the car’s plates and calling the owner of the car. An argument can even be made that contacting the owner wasn’t even necessary, as Mr. Edger’s actions alone were not considered suspicious.

In the officers’ minds, I am sure they were thinking, “We had RAS, we detained him, he failed to I.D. That’s a crime! Let’s book him!” But they failed to properly investigate the situation. And the detainment was no longer reasonable after Mr. Edger provided a reasonable explanation.

It’s obvious to me the officers in this case already had their minds made up when they rolled up to the scene: they wanted to arrest him one way or another. Like most cops, these cops are tyrants. They should be held accountable.

The only thing I disagree with you on your excellent post is that I don’t believe they wanted to arrest him the moment they rolled up. They were fine until he dared to not immediately submit to their demands. It doesn’t make them any less of tyrants, but it shows the mentality of how they want to interact with the public. “I say jump, you jump. Period. If you don’t, you’re going for the ride”

Regarding giving the name and address, I think the case law is pretty clear that the State may demand such information.

In this case petitioner’s refusal to disclose his name was not based on any articulated real and appreciable fear that his name would be used to incriminate him, or that it “would furnish a link in the chain of evidence needed to prosecute” him. Hoffman v. United States, 341 U.S. 479, 486, 71 S.Ct. 814, 95 L.Ed. 1118 (1951). As best we can tell, petitioner refused to identify himself only because he thought his name was none of the officer’s business. Even today, petitioner does not explain how the disclosure of his name could have been used against him in a criminal case. While we recognize petitioner’s strong belief that he should not have to disclose his identity, the Fifth Amendment does not override the Nevada Legislature’s judgment to the contrary absent a reasonable belief that the disclosure would tend to incriminate him.

Hiibel v. Sixth Judicial Dist. Court of Nevada, Humboldt Cnty., 542 U.S. 177, 190–91 (2004).

Whenever the Court is confronted with the question of a compelled disclosure that has an incriminating potential, the judicial scrutiny is invariably a close one. Tension between the State’s demand for disclosures and the protection of the right against self-incrimination is likely to give rise to serious questions. Inevitably these must be resolved in terms of balancing the public need on the one hand, and the individual claim to constitutional protections on the other; neither interest can be treated lightly.

[…]

Disclosure of name and address is an essentially neutral act. Whatever the collateral consequences of disclosing name and address, the statutory purpose is to implement the state police power to regulate use of motor vehicles.

California v. Byers, 402 U.S. 424, 427-32 (1971).

However when it comes to demanding an explanation, if an explanation would constitute an admission of criminal activity, and if the answer is actually used to punish or prosecute the individual, I think that would violate the 5th Amendment.

Here, Martinez was never made to be a “witness” against himself in violation of the Fifth Amendment’s Self–Incrimination Clause because his statements were never admitted as testimony against him in a criminal case. Nor was he ever placed under oath and exposed to “ ‘the cruel trilemma of self-accusation, perjury or contempt.’ ” Michigan v. Tucker, 417 U.S. 433, 445, 94 S.Ct. 2357, 41 L.Ed.2d 182 (1974) (quoting Murphy v. Waterfront Comm’n of N.Y. Harbor, 378 U.S. 52, 55, 84 S.Ct. 1594, 12 L.Ed.2d 678 (1964)). The text of the Self–Incrimination Clause simply cannot support the Ninth Circuit’s view that the mere use of compulsive questioning, without more, violates the Constitution.

[…]

We fail to see how Martinez was any more “compelled in any criminal case to be a witness against himself” than an immunized witness forced to testify on pain of contempt. One difference, perhaps, is that the immunized witness knows that his statements will not, and may not, be used against him, whereas Martinez likely did not. But this does not make the statements of the immunized witness any less “compelled” and lends no support to the Ninth Circuit’s conclusion that coercive police interrogations, absent the use of the involuntary statements in a criminal case, violate the Fifth Amendment’s Self–Incrimination Clause. Moreover, our cases provide that those subjected to coercive police interrogations have an automatic protection from the use of their involuntary statements (or evidence derived from their statements) in any subsequent criminal trial. Oregon v. Elstad, 470 U.S. 298, 307–308, 105 S.Ct. 1285, 84 L.Ed.2d 222 (1985); United States v. Blue, 384 U.S. 251, 255, 86 S.Ct. 1416, 16 L.Ed.2d 510 (1966); Leyra v. Denno, 347 U.S. 556, 558, 74 S.Ct. 716, 98 L.Ed. 948 (1954); Ashcraft v. Tennessee, 322 U.S. 143, 155, 64 S.Ct. 921, 88 L.Ed. 1192 (1944). See also Pillsbury Co. v. Conboy, 459 U.S. 248, 278, 103 S.Ct. 608, 74 L.Ed.2d 430 (1983) (Blackmun, J., concurring in judgment); Williams v. United States, 401 U.S. 646, 662, 91 S.Ct. 1148, 28 L.Ed.2d 388 (1971) (Brennan, J., concurring in result). This protection is, in fact, coextensive with the use and derivative use immunity mandated by Kastigar when the government compels testimony from a reluctant witness. See 406 U.S., at 453, 92 S.Ct. 1653. Accordingly, the fact that Martinez did not know his statements could not be used against him does not change our view that no violation of the Fifth Amendment’s Self–Incrimination Clause occurred here.

Chavez v. Martinez, 538 U.S. 760, 767-70 (2003).

That being said, the only case I can find that references a compelled explanation under the Alabama stop & frisk statute is this dicta,

Under the facts of this case, Officer Neville acted appropriately in investigating the situation. Even without the threat of domestic violence, Officer Neville would have been authorized to stop and investigate. The appellant and his companion had stopped their vehicle in the middle of a public roadway and had turned on the hazard lights—a signal that often indicates that a motorist is in distress. Officer Neville had no way of knowing whether the situation involved simply a motorist in distress or something more sinister, such as domestic violence. Under these facts, he would have been remiss had he not stopped to investigate. Once he stopped, he was entitled to obtain an explanation of the situation from the appellant and his companion. See § 15–5–30, Code of Alabama 1975.

State v. Mitchell, 722 So. 2d 814, 821 (Ala. Crim. App. 1998) (emphasis added).

The Mitchell court did not go into further details because under the facts of the case, the police did not demand an explanation but observed the defendant visibly intoxicated and arrested him for driving under the influence. Self-incrimination was not a consideration in that case.

So ultimately, for me, I would use a two part test.

  1. Would the explanation incriminate the individual, and if so,
  2. Has the explanation been used against him? (including as probable cause for arrest, where before there was only reasonable suspicion)

As a counterexample, I would say the police could compel an individual to disclose where he hid a bomb with only reasonable suspicion to go on, and thus prevent a tragedy, but they couldn’t use any testimony or evidence resulting from that admission to arrest or prosecute the individual, or even extend his detention.

~Max

Excellent post but…

Did the police violate a “clearly established” statutory or constitutional right which is needed to waive qualified immunity?

ISTM the courts have construed that extremely broadly to the point it is a farce.

I am surprised this is a case where the court will test that.

FTR: I am not on the side of the police in this case. What they did was unreasonable in my view (not that my view counts for anything).

Sounds like a weird catch-22. By this standard, if my explanation of my activities might incriminate me, and only if so, then I have a fifth amendment right to remain silent. But if I remain silent, the only way I’m protected from arrest for violating a statute that demands an explanation of my activities is if the officer agrees that my explanation might incriminate me. And the only way an officer could agree that my explanation might incriminate me is if I actually provide that explanation so he can determine whether it would be worthy of fifth-amendment protection - at which point everyone’s heads explode.

I think the fifth amendment has historically not required such tests. During a traffic stop in non-Alabama states, an officer can ask me where I’ve been and what I’m up to, and it’s generally understood that I can refuse to answer, even if I was only buying a candy bar at the corner store. Likewise, I can refuse to consent to a search of my car, even if the only thing in the trunk is a candy bar.

If a court agrees, not the officer.

I would argue that the word “demand” and “explanation” in the Alabama statute distinguish the laws of that state from others. The federal courts have written that a legal obligation to answer police questions (in those cases, name and address) stems from state law, not federal law.

Different right, I don’t think searches are subject to the same analysis. But the same thing happens when an officer searches your car, you have to go to court to vindicate your rights. Then based on how the courts rule, the police will train their officers not to violate people’s rights going forward.

~Max

The law on searches is kind of sui generis (and not really logical) so I wouldn’t try to analogize it. Searches of homes without warrants are a clear no-no absent exigent circumstances. There is very little protection for vehicles because they have historically been “heavily regulated,” so only probable cause is required, not a warrant.

One would think that searches of one’s person would be subject to an elevated standard, and they are - except that under Terry an officer can search a person for weapons with only reasonable suspicion - which pretty much guarantees they’ll find any contraband not kept in a body cavity.

There’s two different issues here-

'If the police has simply asked for his name, then they might have been in the clear. The police can require you to ID yourself.

But they arrested him for refusing to show his ID- which is different, and not required in America.

“Officer McCabe: Are you refusing me—are you refusing to give me your ID or driver’s license?”

The defendants based their qualified immunity claim on Alabama’s “stop and identify statute,” which permits any police officer who “reasonably suspects” a crime is being, has been, or is about to be committed to stop a person in public and “demand of him his name, address and an explanation of his actions.” They argued that Edgar’s refusal to produce identification amounted to probable cause for their warrantless arrest.

The 11th Circuit disagreed and clarified in its ruling that the statute “does not require anyone to produce anything,” and instead, only grants police the right to request specific information — which neither McCabe nor Perillat did.…“We hold that the plain text of the Alabama statute is so clear that no reasonable officer could have believed they could arrest Mr. Edger for failing to produce his ‘ID’ or ‘driver’s license’ under § 15-5-30,” wrote Wilson.

So yeah, maybe they might have gotten away with “Please tell me your name”. But not “you have to show ID”. Note that he did give an explanation for his actions.

True. But only if they suspect the person of committing a crime. Furthermore, the suspicion must be reasonable and articulable.

It’s debatable if the officers had RAS that he committed a crime. IMO they didn’t have it.

Right: unless you’re driving a vehicle, you do not have to possess a state-issued identification card on your person.

Quite debatable. But like I said

I was a passenger in a car driven by a friend who is not the most straight and narrow person I know.

He was pulled over for speeding and got a ticket. The cop asked for my drivers license and I told him no. He looked passed off, but just sighed and dropped it. I actually didn’t have it on me.

Here’s a related hypothetical that popped into my brain:

Let’s say a man robs a bank. In describing the robber, the teller gives a general physical description (medium build, average height, wearing blue jeans and a white t-shirt) but also notes that he spoke with a very distinctive, refined British accent. The cops detain a man a few blocks away who meets the physical description. They ask him to give his name and address, which he does sounding like an Oxford dean.

Can the fact of his accent be used as the basis for an arrest? But for the requirement that he identify himself, he would not have spoken at all. In this case is he being forced to incriminate himself?

I’m not a lawyer, but I suspect it could be used as the basis for continued detention until he, or a photo of him, can be shown to the teller for positive ID.

Yes. It is a factor in determining probable cause. Whether it is admissible in the prosecution is another matter.

There was a federal court case where a suspect was compelled to speak in a similar circumstance, where his voice rather than the words were used against him. As I remember it was like a police lineup but in front of the grand jury; they had each suspect read something the criminal was alleged to have said, from a card, to compare with a recording of the criminal. It’s considered non-testimonial, just like a handwriting sample. I can’t remember the name of the case, though.

ETA: https://www.justice.gov/archives/jm/criminal-resource-manual-256-voice-exemplars-self-incrimination

Compelling a person to give a voice exemplar violates no privilege protected by the Fifth Amendment. The exemplar is used for identification purposes, and is not testimonial or communicative in nature. See United States v. Dionisio , supra . A witness subpoenaed to a grand jury, or a criminal defendant, may thus be compelled to produce voice exemplar, see United States v. Mitchell , 556 F.2d 382 (6th Cir. 1977), and evidence of a refusal to provide a voice exemplar may be introduced, see United States v. Flanagan , 34 F.3d 949, 953-954 (10th Cir. 1994).

~Max