James Gideon v. Matthew Treglia

CourtCourt of Appeals for the Sixth Circuit
DecidedDecember 8, 2025
Docket25-3264
StatusUnpublished

This text of James Gideon v. Matthew Treglia (James Gideon v. Matthew Treglia) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Gideon v. Matthew Treglia, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0568n.06

No. 25-3264

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Dec 08, 2025 KELLY L. STEPHENS, Clerk ) JAMES A. GIDEON, ) Petitioner-Appellant, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR THE v. ) NORTHERN DISTRICT OF OHIO ) ) MATTHEW B. TREGLIA, OPINION ) Respondent-Appellee. )

Before: SILER, KETHLEDGE, and MATHIS, Circuit Judges.

KETHLEDGE, Circuit Judge. James A. Gideon appeals the district court’s denial of his

petition for a writ of habeas corpus. We reject his arguments and affirm.

I.

From 2013 to 2017, Gideon worked as a licensed rheumatologist in Bluffton, Ohio. In

2017, three patients accused him of touching them inappropriately. The accusations prompted a

criminal investigation by the local police department and an administrative one by the State

Medical Board of Ohio.

In the criminal investigation, a police sergeant questioned Gideon about the accusations,

and he denied them. Meanwhile, Chad Yoakam led the administrative investigation. Before

interviewing Gideon, Yoakam met with the police sergeant and they agreed to share information

about the case. Yoakam told the sergeant that Gideon had a statutory duty to cooperate with the

medical board’s investigation; Yoakam also advised the sergeant not to attend the interview, so

that any admissions could be used in a criminal prosecution. No. 25-3264, Gideon v. Treglia

Yoakam later appeared unannounced at Gideon’s office and asked to speak with him.

Gideon was busy with patients, and Yoakam offered to reschedule the interview; but Gideon

declined the offer and agreed to talk with him. Yoakam recorded their conversation without

Gideon’s knowledge. Gideon initially took the lead, and explained why his treatment of patients

involved the use of therapeutic massage. Eighteen minutes into the conversation, however, Gideon

admitted that he had “succumb[ed] to temptation” and touched his patients inappropriately. State

v. Gideon, 176 N.E.3d 720, 727 (Ohio 2020). Afterward, Yoakam told the sergeant that Gideon

had admitted to misconduct. Gideon was later charged with several counts of misdemeanor sexual

imposition under Ohio law.

In the criminal case that followed, Gideon moved to suppress his statements to Yoakam,

arguing that they were compelled in violation of his Fifth Amendment privilege against self-

incrimination. Specifically, Gideon alleged that he had spoken to Yoakam only because, Gideon

believed, he would have lost his medical license had he refused. The trial court held an evidentiary

hearing, during which Gideon, Yoakam, and the police sergeant (among others) testified; the court

also admitted as evidence the audio recording of the interview. The court later denied the motion,

holding that Gideon’s statements to Yoakam were not made under duress. The case proceeded to

trial, where a jury convicted Gideon on three counts. The trial court sentenced him to 180 days in

jail.

Although the state court of appeals reversed on the suppression issue, the Ohio Supreme

Court disagreed and affirmed Gideon’s convictions. The United States Supreme Court denied

certiorari. Gideon later sought habeas relief in federal court, which the district court denied. This

appeal followed.

-2- No. 25-3264, Gideon v. Treglia

II.

To obtain habeas relief, Gideon must show that the Ohio Supreme Court unreasonably

applied United States Supreme Court precedent, or based its decision “on an unreasonable

determination of the facts in light of the evidence presented in the State court proceeding,” when

it affirmed the trial court’s decision. 28 U.S.C. § 2254(d). An unreasonable application of

Supreme Court precedent, for purposes of the habeas statute, is one with which no fairminded

jurist would agree. Harrington v. Richter, 562 U.S. 86, 101 (2011).

Here, the relevant precedents are Garrity v. New Jersey, 385 U.S. 493 (1967), and

Minnesota v. Murphy, 465 U.S. 420 (1984)—which, in Gideon’s view, the Ohio Supreme Court

applied unreasonably when it held that his statements to Yoakam were not coerced.

The Fifth Amendment, applicable to the states through the Fourteenth Amendment,

guarantees that no person “shall be compelled in any criminal case to be a witness against himself.”

Griffin v. California, 380 U.S. 609, 615 (1965). In Garrity, as part of a police internal-affairs

investigation, several officers were expressly warned that, if any of them “refused to answer” an

investigator’s questions—on the ground that an answer “would tend to incriminate” the officer—

then the officer “would be subject to removal from office.” 385 U.S. at 494. The officers then

made self-incriminating statements. The Supreme Court held that the “choice imposed” on the

officers had been “one between self-incrimination or job forfeiture.” Id. at 496. Thus, the Court

held, the statements had been “coerced[.]” Id. at 500.

In Murphy, when confronted by his probation officer, Murphy had admitted that he had

raped and murdered a teenage girl several years before. He was later charged and convicted of

those crimes. On appeal, Murphy made an argument like the one Gideon makes here: that he had

a duty to meet with his probation officer and answer her questions truthfully; that if he refused, his

-3- No. 25-3264, Gideon v. Treglia

probation could be revoked; that his probation officer had “consciously sought incriminating

evidence”; and that his statement was therefore coerced. 465 U.S. at 431. But the Supreme Court

rejected that argument, for several reasons. For one thing—unlike the officers in Garrity—

Murphy had not been expressly threatened with punishment if he invoked his privilege against

incrimination. Id. at 438. For another, if Murphy had thought “his probation might be revoked

for exercising the Fifth Amendment privilege, that belief would not have been reasonable.” Id.

Specifically, the relevant Minnesota statute made clear that “revocation [was] not automatic” if he

violated a condition of his probation; and he would “be afforded a hearing” before his probation

could be revoked. Id. Moreover, the Court was unaware of “any case in which Minnesota has

attempted to revoke probation” on the ground that a probationer had invoked his right against self-

incrimination. Id. at 439. Thus, the Court held, Murphy had not been “deterred from claiming the

privilege by a reasonably perceived threat of revocation.” Id.

The Ohio Supreme Court substantially tracked that same reasoning here. True, Gideon had

a duty to cooperate in the state medical board’s investigation; and true, revocation of Gideon’s

license was one of many possible sanctions if he refused to cooperate. Gideon, 176 N.E.3d at 725.

But the facts in Murphy were materially no different in those respects. Moreover, Gideon had “not

been expressly confronted with the inescapable choice of either making an incriminatory statement

or being fired.” Id. at 726 (cleaned up). In addition, under the applicable Ohio statute, “discipline

is not automatic” for a doctor’s failure to cooperate with an investigation; and even in the event of

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Related

Garrity v. New Jersey
385 U.S. 493 (Supreme Court, 1967)
Minnesota v. Murphy
465 U.S. 420 (Supreme Court, 1984)
Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
State v. Gideon (Slip Opinion)
2020 Ohio 5635 (Ohio Supreme Court, 2020)

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