SCOTUS Rules Miranda Readings Are “Prophylactic”

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

A female patient at a medical center where Terence Tekoh worked complained that he sexually assaulted her. Deputy Vega questioned Tekoh regarding the reported sexual assault of a patient. Deputy Vega did not give Tekoh a Miranda warning. Tekoh wrote a handwritten statement apologizing to the woman, which was later used in his criminal trial for unlawful sexual penetration. The jury found Tekoh not guilty.

Tekoh then sued Vega under 42 U.S.C. § 1983, alleging violations of his constitutional rights, including his Fifth Amendment right against compelled self-incrimination. The 9th Circuit Court of Appeals held 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” against the officer who obtained the statement.

The Court found that the Miranda warnings are “prophylactic” and can require the court to balance competing interests.

A divided Supreme Court reversed. The Court held a violation of Miranda rules does not provide a basis for a section 1983 claim for money damages. The Miranda decision, the Court stated, did not require that a violation of the warning rules necessarily constitute a Fifth Amendment violation. Miranda rules have been described as “constitutionally based” with “constitutional underpinnings,” but a Miranda violation is not the same as a violation of the Fifth Amendment right.

Instead, the Court found that the Miranda warnings are “prophylactic” and can require the court to balance competing interests: “A judicially crafted rule is justified only by reference to its prophylactic purpose, and applies only where its benefits outweigh its costs.” The majority concluded that “while the benefits of permitting the assertion of Miranda claims under § 1983 would be slight, the costs would be substantial.” Thus, Tekoh could not sue Deputy Vega for money damages.

Ken Wallentine

KEN WALLENTINE is the Chief of the West Jordan (Utah) Police Department and former Chief of Law Enforcement for the Utah Attorney General. He has served over four decades in public safety, is a legal expert and editor of Xiphos, a monthly national criminal procedure newsletter. He is a member of the Board of Directors of the Institute for the Prevention of In-Custody Death and serves as a use of force consultant in state and federal criminal and civil litigation across the nation.

More Posts

Share this post:

This blog was featured in our Xiphos newsletter, a monthly legal-focused law enforcement newsletter authored by Ken Wallentine. Subscriptions are free for public safety officers, educators and public attorneys.

Anatomy of a Lawsuit

Related Posts

Back to Top