State v. Graham

{¶ 1} This appeal asks whether the United States Supreme Court’s holding in Garrity v. New Jersey, 385 U.S. 493, 87 S.Ct. 616, 17 L.Ed.2d 562 (1967) — that statements obtained from a public employee under threat of job loss are unconstitutionally coerced and inadmissible in subsequent criminal proceedings— required the trial court to suppress statements by employees of the Ohio Department of Natural Resources (“ODNR”) during an investigation conducted by the Ohio inspector general (“OIG”). We hold that it did.

Facts and Procedural History

{¶ 2} At all relevant times, appellants were five…