Vega v. Tekoh (2022) is the Supreme Court case that ruled a Miranda Rights violation does not provide a basis for relief under 42 U.S. Code § 1983.
Overview:
The case involved the interrogation of Terence Tekoh by the petitioner, Deputy Carlos Vega. Vega questioned Tekoh at Tekoh’s place of employment, but did not inform him of his Miranda rights.
At the end of the questioning, Tekoh provided a written statement that admitted guilt, and was later prosecuted. The written statement was used in trial; but after a jury found Tekoh not-guilty, Tekoh sued Vega under 42 U.S.C § 1983 (Civil Action for Deprivation of Rights).
Decision:
The Supreme Court decided that a violation of Miranda does not necessarily constitute a violation of the Fifth Amendment right against compelled self-incrimination. The Court stated that Miranda imposed “a set of prophylactic rules” but did not hold that a violation of those rules necessarily constituted a Fifth Amendment violation. The Court further determined that post-Miranda decisions (such as Tucker, and Harris) had balanced interests that justified restrictions that would not have been possible if a Miranda violation was a Fifth Amendment violation. Additionally, the Court establishes that “a judicially crafted prophylactic rule” should only apply “where its benefits outweigh its costs.” Here, the Court states that the benefits for allowing a suit would bring only slim benefits while imposing substantial costs on the “judicial economy.”
Implications:
See the following entries re: the impact of this decision: Miranda Warning, Mirandize, Qualified Immunity, Miranda v. Arizona.
[Last updated in August of 2022 by the Wex Definitions Team]