James Gideon v. Matthew Treglia
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.
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NOT RECOMMENDED FOR PUBLICATION File Name: 25a0568n.06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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James Gideon v. Matthew Treglia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-gideon-v-matthew-treglia-ca6-2025.