Vega v. Tekoh - 142 S. Ct. 2095 (2022)

Rule:

42 U.S.C.S. § 1983 provides a cause of action against any person acting under color of state law who “subjects” a person or causes a person to be subjected to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws. A violation of Miranda rules does not provide basis for claim under 42 U.S.C.S. § 1983.

Facts:

The case arose out of the interrogation of respondent Terence Tekoh, by petitioner, Carlos Vega, a County Sheriff ’s Deputy. Petitioner questioned respondent at the medical center where respondent worked regarding the reported sexual assault of a patient. Petitioner did not inform respondent of his rights under Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694. Eventually, respondent provided a written statement apologizing for inappropriately touching the patient’s genitals. Respondent was prosecuted for unlawful sexual penetration. This written statement of respondent was admitted against him at trial. After the jury returned a verdict of not guilty, respondent sued petitioner under 42 U. S. C. §1983, seeking damages for alleged violations of his constitutional rights. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceeding violated the Fifth Amendment and may support a §1983 claim against the officer who obtained the statement.

Issue:

Was the ninth circuit correct in holding that violation of Miranda rights may support a §1983 claim?

Answer:

No.

Conclusion:

The court held that the use of petitioner’s un-Mirandized statement did not provide a valid basis for a claim under 42 U.S.C.S. § 1983 against a police officer. The court explained that a violation of Miranda v. Arizona was not itself a violation of the Fifth Amendment. The Court also saw no justification for expanding Miranda to confer a right to sue under § 1983. The court concluded that Miranda, Dickerson v. United States, and the other cases in that line provided sufficient protection for the Fifth Amendment right against compelled self-incrimination. That, in allowing § 1983 suits based on Miranda claims could also present many procedural issues. Thus, the judgment was reversed, and the case was remanded for further proceedings.