Fifth Amendment privilege (Alabama) · Go Syfert
← Alabama issues

Fifth Amendment privilege in Alabama

142 Alabama opinions name it 4 courts 1968–2024 4 in the last five years

The cases below were cited by Alabama courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (42)

CaseFollowedCited
Miranda v. Arizonagreen
scotus · 1966 · cited in 18 Alabama opinions naming this issue, 1977–2014
2 sentences

2014The Supreme Court in Miranda further held that “the right to have counsel present at the interrogation is indispensable to the protection of the Fifth Amendment privilege....” 384 U.S. at 469 .

2014The Supreme Court in Miranda further held that “the right to have counsel present at the interrogation is indispensable to the protection of the Fifth Amendment privilege....” 384 U.S. at 469 .

918
Ex Parte Baughgreen
ala · 1988 · cited in 13 Alabama opinions naming this issue, 1990–2004
2 sentences

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

613
Beard v. Stategreen
alacrimapp · 1992 · cited in 6 Alabama opinions naming this issue, 1998–2009
2 sentences

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

66
Ex Parte Rawlsgreen
ala · 2006 · cited in 7 Alabama opinions naming this issue, 2006–2024
2 sentences

2024See Ex parte Rawls, 953 So. 2d at 381-82 (granting a petition for the writ of mandamus to stay a divorce trial so that the husband's right against self-incrimination would not be threatened by having to participate in the divorce trial and having to assert his Fifth Amendment privilege in response to certain questions, the answers to which he might deem potentially incriminating).

2024See Ex parte Rawls, 953 So. 2d at 381-82 (granting a petition for the writ of mandamus to stay a divorce trial so that the husband's right against self-incrimination would not be threatened by having to participate in the divorce trial and having to assert his Fifth Amendment privilege in response to certain questions, the answers to which he might deem potentially incriminating).

47
Harry Duncan, Jr. v. Leroy Stynchcombe, Sheriff, Arthur K. Bolton, Attorney Generalgreen
ca11 · 1983 · cited in 5 Alabama opinions naming this issue, 1990–2000
2 sentences

1993See also Biddie v. State , 516 So.2d 837 , 843 (Ala.Cr.App. 1986), reversed on other grounds , 516 So.2d 846 (Ala. 1987)." The United States Court of Appeals for the Eleventh Circuit has held that a prosecutor's comments "on the failure of the defense, as opposed to that of the defendant to counter or explain the testimony presented or evidence introduced is not an infringement of the defendant's Fifth Amendment privilege." Duncan v. Stynchcombe , 704 F.2d 1213 , 1215-16 (11th Cir. 1983) (emphasis added). *Page 1020 In the present case, the prosecutor commented that "neither of the defense att

1993See also Biddie v. State , 516 So.2d 837 , 843 (Ala.Cr.App. 1986), reversed on other grounds , 516 So.2d 846 (Ala. 1987)." The United States Court of Appeals for the Eleventh Circuit has held that a prosecutor's comments "on the failure of the defense, as opposed to that of the defendant to counter or explain the testimony presented or evidence introduced is not an infringement of the defendant's Fifth Amendment privilege." Duncan v. Stynchcombe , 704 F.2d 1213 , 1215-16 (11th Cir. 1983) (emphasis added). *Page 1020 In the present case, the prosecutor commented that "neither of the defense att

45
Schmerber v. Californiagreen
scotus · 1966 · cited in 11 Alabama opinions naming this issue, 1968–2000
2 sentences

1991The Fifth Amendment privilege "does not protect a suspect from being compelled by the State to produce 'real or physical evidence.' [ Schmerber v. California , 384 U.S. 757 ,] 764 [ 86 S.Ct. 1826 , 1832 , 16 L.Ed.2d 908 (1966)].

1991The Fifth Amendment privilege "does not protect a suspect from being compelled by the State to produce 'real or physical evidence.' [ Schmerber v. California , 384 U.S. 757 ,] 764 [ 86 S.Ct. 1826 , 1832 , 16 L.Ed.2d 908 (1966)].

311
Ex Parte Reevesgreen
ala · 1984 · cited in 4 Alabama opinions naming this issue, 1988–1994
2 sentences

1994In Matthews v. State, 611 So.2d 1207, 1212 (Ala.Cr.App.1992), this court held: “ With regard to the privilege against self-incrimination, the “correct” rule is that “a witness, other than the defendant himself, cannot refuse to take the stand and testify by ‘taking the Fifth.’ A witness may only invoke his Fifth Amendment privilege against self-incrimination after he has been sworn and asked a question which would elicit incriminating evidénce if answered by such witness.”’” Quoting Ex parte Reeves, 463 So.2d 177, 178 (Ala.1984).

1991With regard to the privilege against self-incrimination, the “correct” rule is that “a witness, other than the defendant himself, cannot refuse to take the stand and testify by ‘taking the Fifth.’ A witness may only invoke his Fifth Amendment privilege against self-incrimination after he has been sworn and asked a question which would elicit incriminating evidence if answered by such witness.” Reeves v. State, 463 So.2d 174, 176 (Ala.Cr.App.), reversed on other grounds, 463 So.2d 177, 178 (Ala.1984).

34
JDS v. Stategreen
alacrimapp · 1991 · cited in 4 Alabama opinions naming this issue, 1992–2010
2 sentences

2010J.D.S. v. State, 587 So.2d 1249 (Ala.Cr.App.1991).

1992Moreover, this court recently addressed this issue and held: “With regard to the privilege against self-incrimination, the ‘correct’ rule is that ‘a witness, other than the defendant himself, cannot refuse to take the stand and testify by “taking the Fifth.” A witness may only invoke his Fifth Amendment privilege against self-incrimination after he has been sworn and asked a question which would elicit incriminating evidence if answered by such witness.’ Reeves v. State.” J.D.S. v. State, 587 So.2d 1249, 1257 (Ala. Crim.App.1991).

24
Ex Parte Pegramgreen
ala · 1994 · cited in 3 Alabama opinions naming this issue, 2003–2004
2 sentences

2004Baugh, Coastal Training , [ Ex parte ] Pegram , [ 646 So.2d 644 (Ala. 1994)], and Price II.

2004Baugh, Coastal Training , [ Ex parte ] Pegram , [ 646 So.2d 644 (Ala. 1994)], and Price II.

23
Ex Parte Pricegreen
ala · 1997 · cited in 3 Alabama opinions naming this issue, 1999–2004
2 sentences

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

23
Griffin v. Stategreen
alacrimapp · 1981 · cited in 3 Alabama opinions naming this issue, 1996–2000
2 sentences

2000Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App. 1981)." 695 So.2d at 180 (holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendant's innocence was not a comment on the defendant's failure to testify). "`"A prosecutor's statement that the defense has failed to put on evidence as promised by defense counsel is not a comment on the defendant's failure to testify.

2000Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App. 1981)." 695 So.2d at 180 (holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendant's innocence was not a comment on the defendant's failure to testify). "`"A prosecutor's statement that the defense has failed to put on evidence as promised by defense counsel is not a comment on the defendant's failure to testify.

23
Jo Ann Lyons v. Wilbur R. Johnson, Jo Ann Lyons v. F. J. Delarios, Jo Ann Lyons v. F. J. Delariosgreen
ca9 · 1969 · cited in 2 Alabama opinions naming this issue, 2003–2003
22
United States v. Lot 5, Fox Grove, Alachua County, Floridagreen
ca11 · 1994 · cited in 2 Alabama opinions naming this issue, 1996–1996
22
Local 783, Bridge Structural & Ornamental Iron Workers v. BE&K Construction Co.green
scotus · 1995 · cited in 2 Alabama opinions naming this issue, 1996–1996
22
County of Fulton v. Whalengreen
scotus · 1995 · cited in 2 Alabama opinions naming this issue, 1996–1996
22
Parker v. Stategreen
alacrimapp · 1991 · cited in 2 Alabama opinions naming this issue, 1994–1995
22
United States of America, Cross-Appellant v. Jeffery Jackson, Cross-Appelleegreen
ca7 · 1989 · cited in 2 Alabama opinions naming this issue, 1990–1992
22
Smith v. Stategreen
alacrimapp · 1984 · cited in 2 Alabama opinions naming this issue, 1991–1991
22
Reeves v. Stategreen
alacrimapp · 1984 · cited in 2 Alabama opinions naming this issue, 1991–1991
22
Carl D. Wehling and Geraldine D. Wehling v. Columbia Broadcasting Systemgreen
ca5 · 1980 · cited in 7 Alabama opinions naming this issue, 1988–2003
2 sentences

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

17
Ex Parte Ebbersgreen
ala · 2003 · cited in 5 Alabama opinions naming this issue, 2006–2010
2 sentences

2010Thus, the mother "is entitled to assert the Fifth Amendment privilege against self-incrimination. . . [because she] reasonably apprehends a risk of self-incrimination." Ebbers, 871 So.2d at 787 .

2010Thus, the mother "is entitled to assert the Fifth Amendment privilege against self-incrimination. . . [because she] reasonably apprehends a risk of self-incrimination." Ebbers, 871 So.2d at 787 .

15
Larry Thompson v. Louie L. Wainwright, Secretary, Department of Offender Rehabilitationgreen
ca5 · 1979 · cited in 5 Alabama opinions naming this issue, 1988–2009
2 sentences

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

15
Ex Parte McWilliamsgreen
ala · 1993 · cited in 4 Alabama opinions naming this issue, 1996–2000
2 sentences

2000Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App. 1981)." 695 So.2d at 180 (holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendant's innocence was not a comment on the defendant's failure to testify). "`"A prosecutor's statement that the defense has failed to put on evidence as promised by defense counsel is not a comment on the defendant's failure to testify.

2000Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App. 1981)." 695 So.2d at 180 (holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendant's innocence was not a comment on the defendant's failure to testify). "`"A prosecutor's statement that the defense has failed to put on evidence as promised by defense counsel is not a comment on the defendant's failure to testify.

14
Ex Parte Whitegreen
ala · 1989 · cited in 4 Alabama opinions naming this issue, 1990–1997
2 sentences

1997In Ex parte White , 551 So.2d 923 (Ala. 1989), we discussed the interests that must be weighed in a case like this: on the one hand a litigant's interest in asserting the Fifth Amendment privilege, and on the other, the opposing litigant's interest in preventing prejudice that might be caused by a postponement.

1997In Ex parte White , 551 So.2d 923 (Ala. 1989), we discussed the interests that must be weighed in a case like this: on the one hand a litigant's interest in asserting the Fifth Amendment privilege, and on the other, the opposing litigant's interest in preventing prejudice that might be caused by a postponement.

14
New York v. Quarlesgreen
scotus · 1984 · cited in 3 Alabama opinions naming this issue, 1986–2006
2 sentences

1986Berkemer v. McCarty , 468 U.S. 420 , 430 , 104 S.Ct. 3138 , 3145 , 82 L.Ed.2d 317 (1984); see also New York v. Quarles, supra , 467 U.S., at 660 , 104 S.Ct., at 2634 (concurring opinion); Fare v. Michael C. , 442 U.S., [707] at 718, 99 S.Ct., [2560] at 2568. [ 61 L.Ed.2d 197 ] . . ." *Page 699 The Court also wrote, at ___ U.S. ___, 106 S.Ct. at 1144 : "The position urged by respondent would upset this carefully drawn approach in a manner that is both unnecessary for the protection of the Fifth Amendment privilege and injurious to legitimate law enforcement.

1986Berkemer v. McCarty , 468 U.S. 420 , 430 , 104 S.Ct. 3138 , 3145 , 82 L.Ed.2d 317 (1984); see also New York v. Quarles, supra , 467 U.S., at 660 , 104 S.Ct., at 2634 (concurring opinion); Fare v. Michael C. , 442 U.S., [707] at 718, 99 S.Ct., [2560] at 2568. [ 61 L.Ed.2d 197 ] . . ." *Page 699 The Court also wrote, at ___ U.S. ___, 106 S.Ct. at 1144 : "The position urged by respondent would upset this carefully drawn approach in a manner that is both unnecessary for the protection of the Fifth Amendment privilege and injurious to legitimate law enforcement.

13
Griffin v. Californiagreen
scotus · 1965 · cited in 3 Alabama opinions naming this issue, 1968–1997
2 sentences

1997It is clear that 'it is impermissible to penalize an individual for exercising his Fifth Amendment privilege when he is under police custodial interrogation.' *Page 1129 ( Miranda v. State of Arizona (1966), 384 U.S. 436 , 468 , fn. 37, 86 S.Ct. 1602 , 1625 , fn. 37, 16 L.Ed.2d 694 .) This doctrine is a logical extension ( People v. Cockrell (1965) 63 Cal.2d 659 , 47 Cal.Rptr. 788 , 408 P.2d 116 ) of the rule of Griffin v. State of California (1965) 380 U.S. 609 , 85 S.Ct. 1229 , 14 L.Ed.2d 106 , prohibiting comment on the failure of an accused to testify at trial. comment on refusal to testif

1997It is clear that 'it is impermissible to penalize an individual for exercising his Fifth Amendment privilege when he is under police custodial interrogation.' *Page 1129 ( Miranda v. State of Arizona (1966), 384 U.S. 436 , 468 , fn. 37, 86 S.Ct. 1602 , 1625 , fn. 37, 16 L.Ed.2d 694 .) This doctrine is a logical extension ( People v. Cockrell (1965) 63 Cal.2d 659 , 47 Cal.Rptr. 788 , 408 P.2d 116 ) of the rule of Griffin v. State of California (1965) 380 U.S. 609 , 85 S.Ct. 1229 , 14 L.Ed.2d 106 , prohibiting comment on the failure of an accused to testify at trial. comment on refusal to testif

13
Fare v. Michael C.green
scotus · 1979 · cited in 2 Alabama opinions naming this issue, 1986–2009
12
Ohio Adult Parole Authority v. Woodardgreen
scotus · 1998 · cited in 2 Alabama opinions naming this issue, 1999–2004
12
Edwards v. Arizonagreen
scotus · 1981 · cited in 2 Alabama opinions naming this issue, 1983–1999
12
Lefkowitz v. Cunninghamgreen
scotus · 1977 · cited in 2 Alabama opinions naming this issue, 1991–1999
12
Thomas v. Stategreen
alacrimapp · 1985 · cited in 2 Alabama opinions naming this issue, 1988–1995
12
O'CONNOR v. City of Montgomerygreen
alacrimapp · 1984 · cited in 2 Alabama opinions naming this issue, 1994–1995
12
Shockley v. Stategreen
alacrimapp · 1975 · cited in 2 Alabama opinions naming this issue, 1988–1995
12
Allison v. Stategreen
alacrimapp · 1976 · cited in 2 Alabama opinions naming this issue, 1988–1995
12
United States v. Washingtongreen
scotus · 1977 · cited in 2 Alabama opinions naming this issue, 1987–1992
12
Roberts v. United Statesgreen
scotus · 1980 · cited in 2 Alabama opinions naming this issue, 1987–1992
12
Ex Parte State of Alabamagreen
alacrimapp · 1999 · cited in 1 Alabama opinions naming this issue, 2013–2013
11
Rockwood Computer Corp. v. Morrisgreen
nyed · 1982 · cited in 1 Alabama opinions naming this issue, 2009–2009
11
Ex Parte Woodsgreen
ala · 2001 · cited in 1 Alabama opinions naming this issue, 2009–2009
11
Hinds v. Hindsgreen
alacivapp · 2003 · cited in 1 Alabama opinions naming this issue, 2008–2008
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway.

Also cited on this issue (38)

CaseCitedYears
Ex Parte Coastal Training Institute green
ala · 1991
2 sentences

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

91997–2017
Nollie Lee Martin v. Louie L. Wainwright green
ca11 · 1985
2 sentences

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

51988–2009
Hoffman v. United States green
scotus · 1951
2 sentences

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

41991–2003
Malloy v. Hogan green
scotus · 1964
2 sentences

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

2003“The Fifth Amendment privilege against self-incrimination must be liberally construed in favor of the accused, Hoffman v. United States, 341 U.S. 479 , 71 S.Ct. 814 , 95 L.Ed. 1118 (1951), and the privilege is applicable in state as well as in federal proceedings, Malloy v. Hogan, 378 U.S. 1 , 84 S.Ct. 1489 , 12 L.Ed.2d 653 (1964), and in civil as well as in criminal proceedings, Wehling v. Columbia Broadcasting System, 608 F.2d 1084 (5th Cir.1979); Ex parte Baugh, 530 So.2d 238 (Ala.1988).

41992–2003
Baxter v. Palmigiano green
scotus · 1976
2 sentences

2009Although the assertion of a party’s Fifth Amendment privilege in a civil case per *229 mits the trier of fact to draw an adverse inference against the party asserting the privilege, see Baxter v. Palmigiano, 425 U.S. 308, 318 , 96 S.Ct. 1551 , 47 L.Ed.2d 810 (1976), we cannot agree that the assertion of the privilege should be the sole basis for a determination that a summary judgment is due the State in this case.

2009Although the assertion of a party’s Fifth Amendment privilege in a civil case per *229 mits the trier of fact to draw an adverse inference against the party asserting the privilege, see Baxter v. Palmigiano, 425 U.S. 308, 318 , 96 S.Ct. 1551 , 47 L.Ed.2d 810 (1976), we cannot agree that the assertion of the privilege should be the sole basis for a determination that a summary judgment is due the State in this case.

31990–2013
Stewart v. State green
alacrimapp · 1989
2 sentences

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

31992–2009
Bush v. State green
alacrimapp · 1988
2 sentences

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

2009“When a purported invocation of a Fifth Amendment privilege is ambiguous, [however,] the police may question the accused for the narrow purpose of clarifying the equivocal request.” Ex parte Woods, 789 So.2d 941, 946 (Ala.2001) (quoting Beard v. State, 612 So.2d 1335, 1341 (Ala.Crim.App.1992) (citing Martin v. Wainwright, 770 F.2d 918 (11th Cir.1985); Thompson v. Wainwright, 601 F.2d 768 (5th Cir.1979); Stewart v. State, 562 So.2d 1365 (Ala.Crim.App.1989); and Bush v. State, 523 So.2d 538 (Ala.Crim.App.1988))).

31992–2009
Ex Parte Williams green
ala · 2000
2 sentences

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

2004A party need not be indicted to properly claim the Fifth Amendment privilege. [ Ex parte ] Baugh , [ 530 So.2d 238 (Ala. 1988)], [ Ex parte ] Great Escapes Travel , [ Inc. , 573 So.2d 278 (Ala. 1990)], [ Ex parte ] Coastal Training Institute , [ 583 So.2d 979 (Ala. 1991)], [ Ex parte Price , 707 So.2d 1105 (Ala. 1997) (` Price II ')], and [ Ex parte ] Williams , [ 775 So.2d 146 (Ala. 2000)]. "2.

32003–2004
Ex Parte Brooks green
ala · 1997
2 sentences

2003"Further, a prosecutor has the right to indicate to the jury those parts of the evidence or testimony presented by the State that the defense has failed to contradict; that process is not an infringement of the defendant's Fifth Amendment privilege against self-incrimination." Ex parte Brooks, 695 So.2d at 180 . "`The general rule is that statements by the prosecutor to the effect that [the] State's evidence is undenied or uncontroverted are merely indirect references to the defendant's failure to testify and thus do not violate the statute.

2003"Further, a prosecutor has the right to indicate to the jury those parts of the evidence or testimony presented by the State that the defense has failed to contradict; that process is not an infringement of the defendant's Fifth Amendment privilege against self-incrimination." Ex parte Brooks, 695 So.2d at 180 . "`The general rule is that statements by the prosecutor to the effect that [the] State's evidence is undenied or uncontroverted are merely indirect references to the defendant's failure to testify and thus do not violate the statute.

32000–2003
United States v. Wade green
scotus · 1967
2 sentences

1997The government may, for example, compel a person to reenact crime; shave his beard or mustache; try on clothing; dye her hair; demonstrate speech or other physical characteristics;[1930] furnish handwriting samples; hair samples, or fingerprints, have her teeth and gums examined; or take a blood-alcohol, breathalyzer, or urine test. [1930] "See Pennsylvania v. Muniz , 496 U.S. 582 , 592 [ 110 S.Ct. 2638 , 2645 , 110 L.Ed.2d 528 ] (1990) (compelling drunk driving defendant to demonstrate slurred speech and lack of coordination on videotape not Fifth Amendment violation because not testimonial);

1997The government may, for example, compel a person to reenact crime; shave his beard or mustache; try on clothing; dye her hair; demonstrate speech or other physical characteristics;[1930] furnish handwriting samples; hair samples, or fingerprints, have her teeth and gums examined; or take a blood-alcohol, breathalyzer, or urine test. [1930] "See Pennsylvania v. Muniz , 496 U.S. 582 , 592 [ 110 S.Ct. 2638 , 2645 , 110 L.Ed.2d 528 ] (1990) (compelling drunk driving defendant to demonstrate slurred speech and lack of coordination on videotape not Fifth Amendment violation because not testimonial);

31968–1997
Douglas v. Alabama green
scotus · 1965
2 sentences

1995“However, the law with regard to the questioning of witnesses who have invoked their Fifth Amendment privilege against self-incrimination in a refusal to testify is found in the United States Supreme Court decision in Douglas v. Alabama, 380 U.S. 415 , 85 S.Ct. 1074 , 13 L.Ed.2d 934 (1965), wherein that Honorable Court wrote as follows: “ ‘We decide today that the Confrontation Clause of the Sixth Amendment is applicable to the States.

1995“However, the law with regard to the questioning of witnesses who have invoked their Fifth Amendment privilege against self-incrimination in a refusal to testify is found in the United States Supreme Court decision in Douglas v. Alabama, 380 U.S. 415 , 85 S.Ct. 1074 , 13 L.Ed.2d 934 (1965), wherein that Honorable Court wrote as follows: “ ‘We decide today that the Confrontation Clause of the Sixth Amendment is applicable to the States.

31981–1995
Estelle v. Smith green
scotus · 1981
2 sentences

2011Woodward also argues that the trial court’s admission and consideration of the report violated his Fifth Amendment privilege against self-incrimination, and he cites Estelle v. Smith, 451 U.S. 454 , 101 S.Ct. 1866 , 68 L.Ed.2d 359 (1981).

2011Woodward also argues that the trial court’s admission and consideration of the report violated his Fifth Amendment privilege against self-incrimination, and he cites Estelle v. Smith, 451 U.S. 454 , 101 S.Ct. 1866 , 68 L.Ed.2d 359 (1981).

21991–2011
Kastigar v. United States green
scotus · 1972
21999–2006
Mitchell v. United States green
scotus · 1999
21999–2004
Ex Parte Weems green
ala · 1998
22003–2003
United States v. Handley green
ca11 · 1985
22003–2003
Nollie Lee Martin v. Louie L. Wainwright green
ca11 · 1986
21992–2001
Rath Packing Co. Creditors' Trust v. Equal Employment Opportunity Commission green
scotus · 1986
21992–2001
Martin v. Wainwright green
scotus · 1986
21992–2001
Simmons v. Blodgett green
scotus · 1997
22000–2000
Johnson v. Hill green
scotus · 1997
22000–2000
Grahovac v. United States green
scotus · 1997
22000–2000
Brooks v. State green
alacrimapp · 1996
22000–2000
Buchanan v. Kentucky green
scotus · 1987
21991–1999
Pennsylvania v. Muniz green
scotus · 1990
21991–1997
Fisher v. United States green
scotus · 1976
21993–1997
Couch v. United States green
scotus · 1973
21993–1997
Johnson v. State green
alacrimapp · 1976
21988–1995
Thomas Clayton Sanders v. United States green
ca9 · 1967
21975–1995
Allison v. State green
ala · 1976
21988–1995
Marcus T. Baumann v. United States green
ca9 · 1982
21990–1992
John D. Brown v. Robert H. Butler, Jr., Warden, Louisiana State Penitentiary, Respondent green
ca5 · 1987
21990–1992
Lee v. Illinois green
scotus · 1986
21991–1991
United States v. Nobles green
scotus · 1975
21982–1988
United States v. Apfelbaum green
scotus · 1980
21982–1988
Brown v. Illinois green
scotus · 1975
21982–1985
Biles v. State green
alacrimapp · 1997
12010–2010
Lefkowitz v. Turley green
scotus · 1973
12006–2006

Statutes the citing opinions construe

AL § Ala. Code § 13A-5-40 (28) AL § Ala. Code § 13A-5-49 (25) AL § Ala. Code § 13A-5-53 (20) AL § Ala. Code § 13A-5-51 (19) AL § Ala. Code § 13A-5-47 (17) AL § Ala. Code § 13A-5-45 (14) AL § Ala. Code § 13A-5-52 (13) AL § Ala. Code § 13A-6-2 (9) AL § Ala. Code § 12-15-101 (6) AL § Ala. Code § 13A-6-3 (6) AL § Ala. Code § 13A-8-41 (6) AL § Ala. Code § 13A-3-1 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 752 (1959–2026) TX 744 (1967–2026) OH 511 (1966–2026) NY 416 (1956–2026) PA 384 (1963–2026) IL 369 (1959–2026) FL 283 (1966–2025) IN 255 (1970–2026) NJ 234 (1959–2026) MI 232 (1949–2026) MD 212 (1966–2026) WA 207 (1965–2026) TN 204 (1968–2026) DC 181 (1968–2024) CO 177 (1970–2026) LA 169 (1968–2026) AZ 155 (1966–2025) MO 154 (1971–2021) WI 142 (1972–2026) AL 142 (1968–2024) MA 136 (1969–2026) VA 132 (1967–2026) MS 121 (1971–2026) KS 114 (1974–2026) MN 111 (1970–2025) GA 106 (1972–2026) CT 105 (1968–2024) IA 99 (1966–2026) ID 99 (1972–2025) OR 97 (1968–2026) NC 96 (1966–2026) NM 83 (1966–2026) AR 68 (1970–2020) KY 64 (1970–2026) ME 64 (1973–2025) UT 62 (1967–2025) VT 61 (1979–2026) NV 61 (1965–2022) RI 55 (1971–2024) OK 52 (1972–2022) WV 50 (1975–2025) NE 49 (1968–2022) ND 45 (1974–2024) DE 45 (1972–2025) WY 42 (1966–2025) MT 41 (1964–2018) AK 39 (1971–2025) SC 38 (1976–2026) SD 35 (1975–2025) NH 33 (1970–2023) HI 33 (1970–2020) VI 10 (1985–2025) GU 9 (1978–2026) PR 3 (1970–2004) MP 2 (1988–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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