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.
