The court’s decision will cut down on a person’s protection against self-incrimination by excluding the possibility of obtaining compensation. It also means that failure to administer the warning will not expose a law enforcement official to potential harm in a civil lawsuit. However, it will not affect the exclusion of such evidence in a criminal case.
The court clarified that while the Miranda warning protects a constitutional right, the warning is not in itself a right that would trigger the possibility of bringing a civil action.
“Today’s verdict does not get rid of the Miranda court,” said Steve Vladeck, CNN’s Supreme Court analyst and professor at the University of Texas School of Law. “But that makes it much harder to enforce. According to this verdict, the only remedy against a violation of Miranda is to suppress statements obtained from a suspect who is not properly informed of his right to remain silent. But if “If the case never goes to court, or if the government never seeks to use the statement, or if the statement is granted despite the Miranda violation, there is no remedy for the government’s offense.”
Judge Samuel Alito, along with the five other Republican-appointed judges, said that a violation of the Miranda Court “is not in itself a violation of the Fifth Amendment” and that “we see no reason to extend Miranda to grant right to sue, “in accordance with the relevant statutes.
Judge Elena Kagan, along with the other Liberal judges, said the court’s ruling deprived “individuals of the opportunity to seek redress for violations of the law recognized in Miranda.”
“The majority here, as elsewhere, are harming the court by denying the remedy,” she added.
The case involved Terence Tekoh, a hospital worker accused of sexually assaulting an immobilized female patient at a local hospital in 2014.
The question was not whether a defendant should read his Miranda rights, but whether he could sue an officer for damages if he did not receive the Miranda warning for evidence introduced in a criminal case. Lower courts are divided on the issue.
Carlos Vega, a Los Angeles County sheriff’s deputy, questioned Tekoh, though he failed to read to him his rights as required by the 1966 precedent set by Miranda v. Arizona, where the court ruled that a defendant should be warned of a “right to remain silent “.” Under this precedent, without the Miranda Warning, criminal courts are generally barred from granting self-incriminating statements while the defendant was in custody.
Tekoh eventually confessed to the crime, was prosecuted and acquitted – even after the introduction of his confession during the trial. He later sued the officer under a federal law, Section 1983, that allows for damages lawsuits against an official for violating constitutional rights.
The parties disagreed as to whether Vega used coercive techniques to extract an involuntary confession.
Lawyers for Vega said Tekoh’s statement was completely consensual and voluntary and that he was not technically “remanded in custody” at the time, while Tekoh’s lawyers claimed he was bullied into confessing in a room without windows.
Roman Martinez, a lawyer for Vega, said Tekoh could not make his claim because establishing a violation of Miranda does not establish a violation of the Fifth Amendment.
“Miranda establishes a procedural rule that prevents prosecutors from imposing – and courts from admitting – certain unprejudiced statements as part of the prosecution’s main case during a criminal case,” Martinez argued in court papers.
For Martinez, the Miranda Warning is a constitutional rule, it is not a right, and under that interpretation, the trial cannot continue. “Miranda does not prohibit making inadvertent statements; it merely prohibits the subsequent admission of such statements during the trial,” Martinez argued.
He said a decision of an appellate court in favor of Tekoh would “burden police departments nationwide with extraordinary burdens related to lawful and appropriate investigative work.” Any police interaction, according to Martinez, could give rise to a private lawsuit “even where the police officer has acted perfectly lawfully.”
The Biden administration took Vegas’ side.
“Because the Miranda Rule concerns the introduction of evidence during the trial, a suspect must not sue the police officer under Section 1983 for violating that rule,” Attorney General Elizabeth Prelogar argued in court papers.
Lawyers for Tekoh claimed that Vega refused to accept Tekoh’s denials, and that Vega “with a hand resting on his firearm” threatened to report Tekoh and his family members to immigration. Tekoh has a green card and deportation could lead to persecution in Cameroon.
Paul Hoffman, a lawyer for Tekoh, said Vega was “the key player in the chain of events that led directly to the statement being introduced during the trial.”
This story has been updated with further reporting.