Vega v. Tekoh
597 U. S. ____ (2022) (2022)
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Rule of Law:
A violation of the prophylactic Miranda rules does not constitute a deprivation of a constitutional right actionable for damages under 42 U.S.C. §1983, because Miranda warnings are procedural safeguards rather than constitutional rights themselves.
Facts:
- In March 2014, Terence Tekoh was working as a certified nursing assistant at a Los Angeles medical center when a female patient accused him of sexual assault.
- Los Angeles County Sheriff’s Deputy Carlos Vega questioned Tekoh at length at the hospital regarding the accusation.
- Deputy Vega did not inform Tekoh of his rights under Miranda v. Arizona before questioning him.
- Tekoh provided a written statement apologizing for inappropriately touching the patient’s genitals.
- Tekoh was subsequently arrested and charged in California state court with unlawful sexual penetration.
- Tekoh's written statement was admitted into evidence against him at his criminal trials.
- The jury in Tekoh's second criminal trial returned a verdict of not guilty.
Procedural Posture:
- Terence Tekoh was charged in California state court with unlawful sexual penetration.
- At Tekoh’s first criminal trial, the judge held that Miranda had not been violated because Tekoh was not in custody when he provided the statement; this trial resulted in a mistrial.
- At Tekoh’s second criminal trial, a second judge again denied his request to exclude the confession; this trial resulted in an acquittal.
- Tekoh then brought an action under 42 U.S.C. §1983 against Deputy Vega and several other defendants in federal district court, seeking damages for alleged violations of his constitutional rights, including his Fifth Amendment right.
- At the first §1983 trial, the jury returned a verdict in favor of Vega, but the district judge concluded he had given an improper jury instruction and granted a new trial.
- Before the second §1983 trial, the District Court declined Tekoh's request to instruct the jury that a Miranda violation necessarily constituted a Fifth Amendment violation for §1983 liability; instead, the jury was instructed to determine if Tekoh's statement had been "improperly coerced or compelled."
- The jury in the second §1983 trial found in Vega’s favor.
- Tekoh appealed to the United States Court of Appeals for the Ninth Circuit, which reversed, holding that the use of an un-Mirandized statement against a defendant in a criminal proceeding violates the Fifth Amendment and may support a §1983 claim.
- Vega's petition for rehearing en banc was denied by the Ninth Circuit.
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Issue:
Does a violation of the prophylactic rules established in Miranda v. Arizona, leading to the admission of an un-Mirandized statement in a criminal proceeding, provide a basis for a civil claim for damages under 42 U.S.C. §1983 against the officer who obtained the statement?
Opinions:
Majority - justice alito
No, a violation of the Miranda rules does not provide a basis for a civil claim under 42 U.S.C. §1983. The Court clarified that Miranda v. Arizona established a set of prophylactic rules designed to protect the Fifth Amendment right against compelled self-incrimination, but a violation of these rules does not necessarily constitute a violation of the Fifth Amendment itself. Miranda itself did not state that its rules were constitutional rights, but rather "procedural safeguards" or "protective devices." Subsequent cases, such as Harris v. New York and Michigan v. Tucker, affirmed the prophylactic nature of Miranda by allowing exceptions (e.g., for impeachment or the admission of "fruits" of an un-Mirandized statement) that would be impermissible for actual Fifth Amendment violations, consistently engaging in a cost-benefit analysis when defining their scope. While Dickerson v. United States affirmed Miranda as a "constitutional decision" and a "constitutional rule," it did so in the sense that the rules are constitutionally based and binding on the States, thus not subject to abrogation by ordinary legislation, rather than equating a Miranda violation with an outright Fifth Amendment violation. The Court concluded that permitting §1983 claims for Miranda violations would offer little additional deterrent value, while incurring substantial costs by disserving judicial economy through re-adjudicating factual questions already decided in state court and creating friction between federal and state systems. Therefore, the exclusion of unwarned statements at trial, as established by Miranda and its progeny, serves as a complete and sufficient remedy without the need for an additional civil remedy under §1983.
Dissenting - justice kagan
Yes, a violation of the Miranda rules should provide a basis for a civil claim under 42 U.S.C. §1983. The dissent argued that Dickerson v. United States unequivocally established Miranda as a "constitutional rule" and a "constitutional decision" setting a "constitutional minimum" that cannot be abrogated by statute. The Miranda rule grants a corresponding, judicially enforceable right to criminal defendants to have un-Mirandized statements excluded from the prosecution's case-in-chief. This right is "secured by the Constitution" within the meaning of §1983. The majority's distinction that Miranda is merely "prophylactic" and not a direct Fifth Amendment violation is insufficient to deny a §1983 claim, as many constitutional rules are prophylactic in nature, safeguarding deeper constitutional commitments while still being enforceable rights under §1983. Denying individuals the ability to seek redress under §1983 for Miranda violations strips them of a vital component for vindicating cherished constitutional guarantees, especially in cases where an un-Mirandized statement is not suppressed, leading to wrongful conviction.
Analysis:
This case significantly narrows the avenues for seeking redress for alleged Miranda violations by clearly delineating that such violations, while constitutional rules in criminal proceedings, do not give rise to a direct cause of action for damages under 42 U.S.C. §1983. By reinforcing the 'prophylactic' nature of Miranda warnings for civil litigation purposes, the Court limits remedies primarily to the exclusion of evidence in criminal trials. This decision could reduce the number of civil rights lawsuits against police officers and reinforce federalism concerns by avoiding federal courts re-adjudicating state court determinations, but it also means that individuals who suffer harm due to Miranda violations, but are ultimately acquitted or have their statements admitted, will generally lack a civil damages remedy against the offending officer.
