US Supreme Court holds Miranda violation no ground for civil rights claim
MarkThomas / Pixabay
US Supreme Court holds Miranda violation no ground for civil rights claim

The US Supreme Court Thursday held that a Miranda violation is not basis to bring a claim under 42 USC § 1983 in the case of Vega v. Tekoh. 42 USC § 1983 allows for individuals to sue the government for civil rights violations. 

The case first arose when a female patient accused Terrence Tekoh of sexual assault at the Los Angeles medical center where Tekoh worked as a nursing assistant. The accusation was reported to the sheriff’s department. Sheriff deputy Vega responded to the call. Vega questioned Tekoh at the hospital, which resulted in Tekoh giving a written statement and confession. At trial, Tekoh’s requested the confession be inadmissible but the judge denied Tekoh’s motion. The trial ultimately ended in a mistrial. At the second trial the state tried to admit the confession again, but Tekoh was acquitted. 

Tekoh sued Vega for damages under 42 USC § 1983. The trial-level the jury found in favor of Vega.  Tekoh appealed to the US Court of Appeals for the Ninth Circuit. The court found in favor of Tekoh and overturned the  jury’s verdict. 

Justice Alito wrote the majority opinion in the Supreme Court’s 6-3 decision. Alito wrote: “A violation of Miranda is not itself a violation of the Fifth Amendment.” Traditionally under Miranda v. Arizona, legal officers are required to provide individuals with their legal rights during an arrest. There was also a question of whether Tekoh was in custody, which Alito resolved by stating that the state court already decided that when they found Tekoh was not in custody. Alito closed the majority opinion by writing, “[w]e see no justification for expanding Miranda to confer a right to sue under §1983.”

Justice Kagan wrote the dissent, joined by Justice Breyer and Justice Sotomayor. Kagan stated that Miranda  rights are “secured by the Constitution” which allows a person to sue under 42 U.S.C. § 1983. Kagan ended her dissent in stating: “Today, the Court strips individuals of the ability to seek a remedy for violations of the right recognized in Miranda.”

The court on Thursday also held that 42 U.S.C. § 1983 was appropriate for capital defendants to challenge their execution in Nance v. Ward.