State v. Flores, 2026 Minn. App. Unpub. LEXIS 447 (Minn. Ct. App. 2026)

The Minnesota Court of Appeals held that statements made to a child welfare investigator after invoking the right to counsel are inadmissible under Miranda, finding that the investigator was acting as an arm of the state. The court reasoned:

The central issue on appeal therefore narrows to whether Flores’s invocation of his Miranda rights bars not only official police questioning but also Investigator Rooney’s questioning. We are satisfied that the answer is yes, notwithstanding that Investigator Rooney was employed as a social worker rather than a police officer, to maintain the purpose of a Miranda warning. Miranda warnings safeguard a person’s Fifth Amendment right against self-incrimination during a custodial interrogation by law enforcement. See State v. Horst, 880 N.W.2d 24, 30 (Minn. 2016). Law enforcement includes anyone who uses the “power of the state” to induce an incriminating response. State v. Tibiatowski, 590 N.W.2d 305, 310 (Minn. 1999). In this case, Investigator Rooney fits that description.

Investigator Rooney qualified as law enforcement by acting as an arm of the state when she exercised her statutory duty as a social worker to obtain informative, incriminating interview statements from Flores after he was accused of sexually assaulting June. We focus on the investigator’s role and not merely her title when determining whether a Miranda warning must precede a government agent’s questioning. Mathis v. United States, 391 U.S. 1, 4-5 (1968). The Mathis Court held that Miranda applied to an IRS agent’s questioning of an incarcerated defendant in a civil investigation. Id. at 2-4.