Vega v. Tekoh: Miranda violations do not support Sec. 1983 actions
Section 1983 actions cannot be brought for violation of Miranda rights, the U.S. Supreme Court held June 23 in Vega v. Tekoh.
Terence Tekoh, who worked as a nursing assistant, was suspected of sexual abusing a patient.
Deputy Carlos Vega, of the Los Angeles Sheriff’s Department, questioned him and obtained an incriminating statement, without giving Miranda rights.
The California trial court refused to suppress the statement, but Tekoh was later acquitted at trial.
Tekoh then brought a Sec. 1983 action in U.S. District Court against Deputy Vega, alleging Vega violated Tekoh’s Miranda rights.
The District Court dismissed the case on grounds that Miranda established a prophylactic rule that could not alone provide grounds for a Sec. 1983 action.
The Ninth Circuit reversed.
The Supreme Court, in a 6-3 opinion, held that violation of Miranda cannot support a Sec. 1983 action.
“[T]he Ninth Circuit held … that a violation of Miranda constitutes a violation of the Fifth Amendment right against compelled self-incrimination, but that is wrong,” the Court said. “Miranda itself and our subsequent cases make clear that Miranda imposed a set of prophylactic rules.”
The warnings the Court required in Miranda “do not concern self-incrimination per se but are instead plainly designed to safeguard that right,” the Court said.
Section 1983 provides causes of action against government officials who deprive people of rights, privileges, or immunities secured by “the Constitution and laws,” the Court said.
A violation of Miranda does not constitute a deprivation of a right secured by the Constitution or federal law, the Court said.
“Miranda rests on a pragmatic judgment about what is needed to stop the violation at trial of the Fifth Amendment right against compelled self-incrimination,” the Court said. “That prophylactic purpose is served by the suppression at trial of statements obtained in violation of Miranda,” the Court said.
Allowing Sec. 1983 suits for Miranda violations would open federal courts to having to resolve a number of procedural issues, such as what deference is owed to state courts’ findings on Miranda, the Court said.
“We see no justification for expanding Miranda to confer a right to sue under Sec. 1983,” the Court concluded.
Justice Kagan dissented, joined by Justices Breyer and Sotomayor.
A wrongly convicted person may spend years in prison for having statements admitted against him, in violation of Miranda, and have his conviction eventually reversed on appeal or in habeas, Kagan said.
“But then, what remedy does he have for all the harm he has suffered?” she said. “The point of Sec. 1983 is to provide such redress.”
“The majority here … injures the right by denying the remedy,” she concluded.