State of Ohio v. James A. Gideon, Case No. 2019-1104
Third District Court of Appeals (Allen County)

ISSUES:
Appeal -
- When a nongovernment employee gives a statement to a state administrative board/licensing agency and there isn't a threat of loss of employment, is that employee's statement subject to the U.S. Supreme Court's ruling in Garrity v. New Jersey (1967)?
Cross-Appeal -
- Did licensing board investigator's actions strongly weigh in favor of finding that the doctor had an objectively reasonable belief that asserting his constitutional right against self-incrimination would expose him to revocation of his license and loss of his livelihood?
- Does an appellate court have a duty to review claims of insufficiency of evidence or of an error that is likely to become an issue on remand?