U.S. Supreme Court Says Infringement of Individual’s Miranda Rights Is Not a Basis for a Claim Under § 1983. | Cranfill Sumner LLP
In a recent opinion, the United States Supreme Court overturned a decision of the Ninth Circuit Court of Appeals in which it held that “the use of aMirandized statement against a defendant in a criminal proceeding violates the Fifth Amendment and may support a complaint under § 1983” against the officer who obtained the statement. The 6 to 3 majority found that Miranda does not extend to claims made under 42 USC § 1983.
This case stems from an interrogation in custody of Terrance Tekoh in March 2014. At that time, Tekoh was working as a certified practical nurse at a medical center in Los Angeles. When a patient accused him of sexually assaulting her, hospital staff reported the accusation to the Los Angeles County Sheriff’s Department, and Deputy Carlos Vega responded. Vega questioned Tekoh at length at the hospital, and Tekoh eventually provided a written statement apologizing for inappropriately touching the patient’s genitals. Relevant to the issue at the center of this case, it was undisputed that Deputy Vega never advised Tekoh of his rights under Miranda v. Arizona384 US 436 (1966) during his interrogation.
Tekoh was later arrested and charged in California state court with unlawful sexual penetration. During Tekoh’s criminal trial, the government presented itsMirandized written statement. This lawsuit resulted in an acquittal, and Tekoh later filed a lawsuit under 42 USC § 1983 against Vega and several other defendants seeking damages for alleged violations of his constitutional rights, including his right to fifth amendment against forced self-incrimination. The United States Court of Appeals for the Ninth Circuit agreed with Tekoh, finding that the government’s use of the UN-Mirandized statement provided a basis on which Tekoh could seek civil damages under Section 1983.
A Miranda violation does not provide a basis for a claim under section 1983
The Supreme Court rejected the Ninth Circuit’s finding that the use of aMirandized statement provided a basis upon which an individual could seek civil damages under Section 1983. The majority opinion, written by Judge Samuel Alito, prefaced its reasoning with the following statement:[i]FA Miranda violation amounted to a violation of the Fifth Amendment, our response would of course be different. The majority later held that “[a]t no point in the [Miranda] The court said a violation of its new rules was a violation of the Fifth Amendment right against coerced self-incrimination. Furthermore, the Court found that none of his post-Miranda rulings characterize it as something other than a Fifth Amendment safeguard, that’s to say., an additional procedural protection which performed the prophylactic function of safeguarding “this right during interrogation in custody”. Therefore, according to the majority, Miranda and its rules are distinct from a constitutional right and a violation of it does not amount to a violation of the Fifth Amendment. Given the distinction made between Miranda and the Fifth Amendment, the majority held that a plaintiff could not sue under Section 1983 based on the allegation of disenfranchisement of constitutional rights for a Miranda breach. He concluded that “except in unusual circumstances, ‘the exclusion of uninformed statements’ should be ‘a full and sufficient remedy'”.
Justice Kagan, writing a dissenting opinion joined by Justices Sotomayor and Breyer, said the majority does not award redress to people whose rights were violated by police under Miranda. Dissent leans heavily on case Dickerson v. United States530 US 428 (2000), to argue that Miranda actually conferred a constitutional right and that, therefore, violations of it could form the basis of an action under section 1983. Justice Kagan also lamented the consequences for some defendants whose constitutional rights were been violated and who can no longer seek redress under Section 1983, “an essential part of any system for asserting the most cherished constitutional guarantees”.
Whereas Miranda caveats are always necessary to protect an individual’s Fifth Amendment right, the Court made it clear that it was unwilling to extend Mirandaprotections in any way. The protections offered by Miranda focus on removing un-Mirandized confessions and cannot be used as a basis for civil remedies under section 1983. More generally, this case is further demonstration that the Supreme Court, as presently constituted, is not interested in expanding the additional remedies for constitutional violations that Congress itself has made not fashionable. However, nothing in this ruling prevents Congress from doing so in response. Regardless, law enforcement officers should be diligent in providing Miranda warnings to avoid situations such as Vega.