SupremeToday Landscape Ad
Back
Next
Judicial Analysis Court Copy Headnote Facts Arguments Court observation
Listen Article Pause Article
judgment-img

2022 Supreme(US)(scotus) 678

SUPREME COURT OF THE UNITED STATES
Samuel Alito
Vega – Appellant
Versus
Tekoh – Respondent



Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus

VEGA v. TEKOH CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

No. 21–499. Argued April 20, 2022—Decided June 23, 2022 The case arose out of the interrogation of respondent, Terence Tekoh, by petitioner, Los Angeles County Sheriff ’s Deputy Carlos Vega. Deputy Vega questioned Tekoh at the medical center where Tekoh worked re- garding the reported sexual assault of a patient. Vega did not inform Tekoh of his rights under Miranda v. Arizona, 384 U. S. 436. Tekoh eventually provided a written statement apologizing for inappropri- ately touching the patient’s genitals. Tekoh was prosecuted for unlaw- ful sexual penetration. His written statement was admitted against him at trial. After the jury returned a verdict of not guilty, Tekoh sued Vega under 42 U. S. C. §1983, seeking damages for alleged violations of his constitutional rights. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceed- ing violates the Fifth Amendment and may support a §1983 claim against the officer who obtained the statement. Held: A violation of the Miranda rules does not provide a basis for a §1983 claim. Pp. 4–16. (a) Section 1983 provides a cause of action against any person acting under color of state law who “subjects” a person “to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws.” Tekoh argues that a violation of Miranda constitutes a violation of the Fifth Amendment right against compelled self-incrimination. That is wrong. Pp. 4–13. (1) In Miranda, the Court concluded that additional procedural pro- tections were necessary to prevent the violation of the Fifth Amend- ment right against self-incrimination when suspects who are in cus- tody are interrogated by the police. Miranda imposed a set of prophylactic rules requiring that custodial interrogation be preceded 2 VEGA v. TEKOH

Syllabus

by now-familiar warnings and disallowing the use of statements ob- tained in violation of these new rules by the prosecution in its case-in- chief. 384 U. S., at 444, 479. Miranda did not hold that a violation of the rules it established necessarily constitute a Fifth Amendment vio- lation. That makes sense, as an un-Mirandized suspect in custody may make self-incriminating statements without any hint of compulsion. The Miranda Court stated that the Constitution did not itself require “adherence to any particular solution for the inherent compulsions of the interrogation process” and that its decision “in no way create[d] a constitutional straitjacket.” Id., at 467. Since Miranda, the Court has repeatedly described Miranda rules as “prophylactic.” Pp. 4–7. (2) After Miranda, the Court engaged in the process of charting the dimensions of these new prophylactic rules, and, in doing so, weighed the benefits and costs of any clarification of the prophylactic rules’ scope. See Maryland v. Shatzer, 559 U. S. 98, 106. Some post-Mi- randa decisions found that the balance of interests justified re- strictions that would not have been possible if Miranda described the Fifth Amendment right as opposed to a set of rules designed to protect that right. For example, in Harris v. New York, 401 U

Click Here to Read the rest of this document
1
2
3
4
5
6
7
8
9
10
11
SupremeToday Portrait Ad
supreme today icon
whatsapp-icon Back to top