Vega v. Tekoh: You Cannot Sue the Police for Violating Your Miranda Rights

Miranda warnings are an integral part of our justice system that are intended to protect one's privilege against self-incrimination and right to counsel under the United States Constitution. The text of the Miranda warning has become part of our culture to the extent that anyone who has watched a moderate number of shows or movies that deal with crime or the police can recite at least part of the words, which begin with "You have the right to remain silent….

It has long been accepted that a confession given by a non-Mirandized suspect in custody is not admissible. Recently, in Vega v Tekoh, the United States Supreme Court took up the question as to whether a person who was denied a Miranda warning and had their statement used against them in court could sue. The Court answered in the negative, meaning that people whose 5th and 6th Amendment rights are violated have no recourse against the government.

The Facts of Vega v. Tekoh

Carlos Vega, a sheriff's deputy in Los Angeles County, was looking into a case where a patient who couldn't move was said to have been sexually assaulted at a hospital. The woman pointed to Terence Tekoh as the person responsible. Vega talked to Tekoh at the hospital, and Tekoh admitted to the assault by signing a confession.

When Tekoh was on trial, two judges decided that the confession could be used as evidence even though Vega did not Mirandize Tekoh when he questioned him. The judges allowed the confession because Tekoh wasn't considered to be in custody when Vega talked to him.

At Tekoh's trial, after listening to what Tekoh and his co-workers said, which was different from what Vega said, and after hearing from an expert about interrogation methods that might be forceful, the jury decided that Tekoh was not guilty.

The Supreme Court’s Reasoning

Justice Samuel Alito wrote the main opinion for the Court, holding that 

A violation of the Miranda rules doesn't automatically give you the right to file a § 1983 claim.

The majority reasoned that Miranda established certain precautionary rules that require police officers to issue warnings before questioning someone in custody and prohibits the use of statements obtained in violation of these rules. However, a breach of Miranda doesn't necessarily mean the Fifth Amendment has been violated. Expanding Miranda rules to allow individuals to sue for damages under 42 U.S.C. § 1983 would provide limited benefits and burden the judicial system with substantial costs.

Justice Elena Kagan wrote a dissenting opinion, which Justices Stephen Breyer and Sonia Sotomayor supported. They argued that prior court decisions recognize Miranda as granting a constitutional right. Therefore, if this constitutional right is violated, individuals should be able to make a claim under 42 U.S.C § 1983.

Call Us Today to Speak with an Eau Claire Criminal Defense Lawyer

If you are facing criminal charges or believe the police have violated your rights, you should speak to an attorney as soon as you can. At Cohen Law Offices, we know how to protect our rights and will do everything possible to bring your case to a favorable resolution. To schedule a consultation with a criminal defense attorney in Eau Claire, call our office today or contact us online.