[21-499] Vega v. Tekoh

Vega v. Tekoh

Wikipedia · Justia (with opinion) · Docket · oyez.org

Argued on Apr 20, 2022.
Decided on Jun 23, 2022.

Petitioner: Carlos Vega.
Respondent: Terence B. Tekoh.

Advocates:

• Roman Martinez (for the Petitioner)
• Vivek Suri (for the United States, as amicus curiae, supporting the Petitioner)
• Paul L. Hoffman (for the Respondent)

Facts of the case (from oyez.org)

Terence Tekoh worked as a patient transporter in a hospital in Los Angeles. After a patient accused him of sexual assault, hospital staff reported the allegation to the Los Angeles Sheriff’s Department. Deputy Carlos Vega went to the hospital to ask Tekoh some questions and to take Tekoh’s statement. Although the parties described vastly different accounts of the nature of the interaction between Tekoh and Vega, it is undisputed that Vega did not advise Tekoh of his Miranda rights prior to questioning him or taking his statement.

Tekoh was arrested and charged in California state court, but a jury returned a verdict of not guilty. Following the acquittal on the criminal charge, Tekoh sued Vega under 42 U.S.C. § 1983 alleging that Vega violated Tekoh’s Fifth Amendment right against self-incrimination by taking his statement without first advising him of his Miranda rights.

Based on the district court’s instructions, a jury found for Vega. The U.S. Court of Appeals for the Ninth Circuit vacated the verdict, reversed the district court’s judgment, and remanded the case for a new trial.

Question

Is the use of an un-Mirandized statement against a defendant in a criminal case sufficient to support a 42 U.S.C. § 1983 action?

Conclusion

A violation of the Miranda rules does not provide a basis for a § 1983 claim. Justice Samuel Alito authored the majority opinion of the Court.

Miranda imposed a set of prophylactic rules requiring that police officers issue warnings before a custodial interrogation and disallowing the use of statements obtained in violation of those rules. A Miranda violation is not necessarily a Fifth Amendment violation. Expansion of Miranda rules to provide a right to sue for damages under 42 U.S.C. § 1983 would provide very little benefit and would impose substantial costs on the judicial system.

Justice Elena Kagan authored a dissenting opinion, in which Justices Stephen Breyer and Sonia Sotomayor joined, arguing that the Court’s precedents recognize Miranda as conferring a constitutional right, and as such, violation of that constitutional right should be sufficient to support a claim under 42 U.S.C § 1983.