SCOTUS Rules on Civil Recourse in Miranda Mishaps
The Supreme Court ruled this past Thursday on whether individuals may sue officers who violate their “Miranda Rights,” and in a 6-3 decision, the High Court ruled no.
The case, Vega V. Tekoh, arose after Terence Tekoh was charged with sexual assault and criminally prosecuted after providing a written confession to Deputy Carlos Vega during an interrogation where he failed to read Mr. Tekoh his “Miranda Rights”. This “un-Mirandized” confession was later admitted as evidence in Mr. Tekoh’s criminal trial, and while he was ultimately found not guilty by the jury, he later sued Deputy Vega under 42 U. S. C. §1983, seeking damages for alleged violations of his constitutional rights.
The case presented a specific question to the Supreme Court: Does a violation of the Miranda rules provide a basis for a §1983 suit? The majority opinion, delivered by Justice Alito, ruled it does not, explaining that a Miranda violation is not equivalent to a violation of the Fifth Amendment and therefore does not provide a constitutional right to sue under the federal law.
In the majority opinion, Justice Alito explained the following:
“Miranda rests on a pragmatic judgment about what is needed to stop the violation at trial of the Fifth Amendment right against compelled self-incrimination… Allowing the victim of a Miranda violation to sue a police officer for damages under §1983 would have little additional deterrent value, and permitting such claims would cause many problems.”
“What all this boils down to is basically as follows. The Miranda rules are prophylactic rules that the Court found to be necessary to protect the Fifth Amendment right against compelled self-incrimination. In that sense, Miranda was a “constitutional decision” and it adopted a “constitutional rule” because the decision was based on the Court’s judgment about what is required to safeguard that constitutional right.”
The minority opinion of the court took a fundamentally opposite approach to the issue, claiming that the Miranda rule itself grants a corresponding right, and therefore, a person should be able to sue an individual state actor (under §1983) who deprives them of such rights.
Justice Kagan stated the following in the dissenting opinion:
“Today, the Court strips individuals of the ability to seek a remedy for violations of the right recognized in Miranda. The majority observes that defendants may still seek “the suppression at trial of statements obtained” in violation of Miranda’s procedures… But sometimes, such a statement will not be suppressed. And sometimes, as a result, a defendant will be wrongly convicted and spend years in prison. He may succeed, on appeal or in habeas, in getting the conviction reversed. But then, what remedy does he have for all the harm he has suffered? The point of §1983 is to provide such redress—because a remedy “is a vital component of any scheme for vindicating cherished constitutional guarantees.”
Justice Kagan continued to explain:
“Dickerson v. United States tells us in no uncertain terms that Miranda is a “constitutional rule.”… And that rule grants a corresponding right: If police fail to provide the Miranda warnings to a suspect before interrogating him, then he is generally entitled to have any resulting confession excluded from his trial… From those facts, only one conclusion can follow—that Miranda’s protections are a “right” “secured by the Constitution” under the federal civil rights statute… Yet the Court today says otherwise. It holds that Miranda is not a constitutional right enforceable through a §1983 suit. And so it prevents individuals from obtaining any redress when police violate their rights under Miranda. I respectfully dissent.”
Justice Alito was joined in his majority opinion by Justices Roberts, Thomas, Gorsuch, Kavanaugh and Barrett. Justice Kagan was joined in her dissent by Justices Breyer and Sotomayor.
ALEC model policies such as the Resolution in Support of Establishing Efficient and Fair Criminal Law Discovery Practices, the Grand Jury Due Reform Act, the Criminal Intent Protection Act and the Treating Accused Persons Fairly Act, all aim to provide states with the most fair and just criminal trial guidelines to better uphold the constitutional rights of those who are criminally accused.