Deputy Carlos Vega of the Los Angeles County Sheriff’s Department responded to an LA-area hospital after a female patient reported that she had been sexually assaulted by Terence Tekoh, a CNA who worked at the hospital. Upon arrival, Vega questioned Tekoh extensively without advising him of his rights pursuant to Miranda v. Arizona, ultimately obtaining a written statement of apology from him.
At Tekoh’s criminal trial, the statement was admitted over Tekoh’s objection, but he was acquitted nonetheless. Thereafter, Tekoh filed a §1983 suit against Vega, arguing that a state actor’s violation of Miranda constitutes the deprivation of a right “secured by the Constitution” or by “laws” for which §1983 authorizes suit.
In a 6-3 decision, the Supreme Court disagreed. First, the majority reviewed Miranda and its progeny, emphasizing the prophylactic nature of the rules espoused there. Although they were judicially crafted to protect a Constitutional right, they are distinct from the Constitutional right itself. Therefore, the Court held, Miranda rights are not ones “secured by the Constitution” for purposes of seeking relief pursuant to §1983.
Second, the majority considered whether Miranda warnings were ones secured by federal “law.” To answer that question in the affirmative, the majority said, would require it to extend a judicially-crafted, prophylactic rule to a new context—civil damages—which the court declined to do.
Justice Kagan dissented, arguing that even though Miranda rules may be defined as prophylactic, Dickerson made clear that Miranda set forth a constitutional minimum for what’s required by the Fifth Amendment. Thus, Miranda warnings are “rights” that are explicitly rooted in—i.e., “secured by”—the Constitution.
Certiorari to the Ninth Circuit
Opinion by Alito, joined by Roberts, Thomas, Gorsuch, Kavanaugh, and Barrett.
Dissent by Kagan, joined by Breyer and Sotomayor
Click here to read the opinion.