Are Statements Made by a Prisoner to a Caseworker Admissible In a Criminal Case ?

In Commonwealth v. Ramos, 367 Pa. Super. 84, 532 A.2d 465 (Pa. Super. 1987), the defendant was in prison when he was interviewed by a caseworker investigating his abuse case. Although he had invoked his right to remain silent in the presence of a state trooper, requested the appointment of a lawyer and refused to answer any questions posed by police, he made incriminating statements to the caseworker. Those statements were transmitted by the caseworker to the police and later offered against the appellant in his criminal case. This court held that because the Child Protective Services Law required the caseworker to turn the statement over to police, the caseworker was akin to a police agent and so the statements made by the defendant had to be suppressed in the criminal case.