State v. Jackson (Slip Opinion), 116 N.E.3d 1240

In August 2015 a 14‑year‑old alleged victim reported sexual assault; police arrested Demetrius Jackson, who invoked Miranda and refused to speak to detectives.
Cuyahoga County Division of Children and Family Services (CCDCFS) opened an investigation; social worker Holly Mack (assigned to jail and experienced interviewing alleged perpetrators) interviewed Jackson in jail without giving Miranda warnings.
Mack told Jackson she was identifying allegations and that his statements "can be subpoenaed," after which he provided a version of events; Mack later testified at trial about his statements.
Jackson was convicted at a bench trial of two counts of rape and kidnapping; on appeal the Eighth District reversed, holding Mack was an agent of law enforcement and her custodial interrogation required Miranda and counsel protections.
The State appealed to the Ohio Supreme Court on the question whether a children‑services social worker’s statutory duty to cooperate with police makes the worker a law‑enforcement agent for Fifth and Sixth Amendment purposes.
The Ohio Supreme Court reversed the appellate court, holding statutory cooperation alone does not make a social worker an agent of law enforcement absent evidence the worker acted under law‑enforcement direction or control.

Issue	Plaintiff's Argument (Jackson)	Defendant's Argument (State)	Held
Whether a children‑services social worker becomes a law‑enforcement agent (triggering Miranda) simply because of a statutory duty to cooperate and share reports with police	Statutory duty and routine collaboration with police (plus Mack’s jail assignment and role) made Mack the functional equivalent of law enforcement; Miranda and Sixth Amendment counsel protections therefore apply	Miranda applies only to law‑enforcement officers or their agents; statutory duty to cooperate does not by itself create agency absent direction/control by police	Reversed appellate court: statutory duty to cooperate does not automatically make social worker an agent; agency requires evidence of direction or control by law enforcement
Whether admission of the social worker’s testimony violated the Sixth Amendment right to counsel	Admission of an agent’s unwarned custodial statements violated right to counsel once adversary process began; Mack was effectively an agent	Because Mack was not an agent, Sixth Amendment protections were not triggered for her interview	Because Mack was not shown to be acting under police control, Sixth Amendment ruling by appellate court was erroneous; testimony admissible on that ground

Miranda v. Arizona, 384 U.S. 436 (establishes custodial‑interrogation warnings requirement)
Estelle v. Smith, 451 U.S. 454 (court‑appointed examiners can become functional agents of the State when their role shifts to providing evidence for prosecution)
Mathis v. United States, 391 U.S. 1 (Miranda may apply to non‑police federal agents acting as functional equivalents of law enforcement)
Kansas v. Ventris, 556 U.S. 586 (Sixth Amendment right to counsel applies at critical pretrial interactions, including deliberate elicitation by law‑enforcement agents)
Ohio v. Clark, 135 S. Ct. 2173 (mandatory reporting statutes alone do not convert private conversations into law‑enforcement missions for confrontation‑clause purposes)
State v. Watson, 28 Ohio St.2d 15 (Miranda applies to officers or their agents, not to non‑agents)
State v. Roberts, 32 Ohio St.3d 225 (discusses Miranda in context of custodial questioning by supervisory figures and the pressures on subjects)
Jackson v. Conway, 763 F.3d 115 (2d Cir.) (caseworker interview of in‑custody suspect who had invoked Miranda found to implicate Fifth Amendment when worker functioned as law‑enforcement equivalent)