Vega v. Tekoh
597 U.S. ____ (2022)
(Case Syllabus had been edited by Author.)
The case arose out of the interrogation of respondent, Terence Tekoh, by petitioner, Los Angeles County Sheriff’s Deputy Carlos Vega. Deputy Vega questioned Tekoh at the medical center where Tekoh worked regarding the reported sexual assault of a patient. Vega did not inform Tekoh of his rights under Miranda v. Arizona, 384 U. S. 436. Tekoh eventually provided a written statement apologizing for inappropriately touching the patient’s genitals. Tekoh was prosecuted for unlawful sexual penetration. His written statement was admitted against him at trial. After the jury returned a verdict of not guilty, Tekoh sued Vega under 42 U. S. C. §1983, seeking damages for alleged violations of his constitutional rights. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceeding violates the Fifth Amendment and may support a §1983 claim against the officer who obtained the statement.
Held: A violation of the Miranda rules does not provide a basis for a §1983 claim.
(a) Section 1983 provides a cause of action against any person acting under color of state law who “subjects” a person “to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws.” Tekoh argues that a violation of Miranda constitutes a violation of the Fifth Amendment right against compelled self-incrimination. That is wrong.
(1) In Miranda, the Court concluded that additional procedural protections were necessary to prevent the violation of the Fifth Amendment right against self-incrimination when suspects who are in custody are interrogated by the police. Miranda imposed a set of prophylactic rules requiring that custodial interrogation be preceded by now-familiar warnings and disallowing the use of statements obtained in violation of these new rules by the prosecution in its case-in-chief. 384 U. S., at 444, 479. Miranda did not hold that a violation of the rules it established necessarily constitute a Fifth Amendment violation. That makes sense, as an un-Mirandized suspect in custody may make self-incriminating statements without any hint of compulsion. The Miranda Court stated that the Constitution did not itself require “adherence to any particular solution for the inherent compulsions of the interrogation process” and that its decision “in no way create[d] a constitutional straitjacket.” Id., at 467. Since Miranda, the Court has repeatedly described Miranda rules as “prophylactic.”
(2) After Miranda, the Court engaged in the process of charting the dimensions of these new prophylactic rules, and, in doing so, weighed the benefits and costs of any clarification of the prophylactic rules’ scope. See Maryland v. Shatzer, 559 U. S. 98, 106. Some post-Miranda decisions found that the balance of interests justified restrictions that would not have been possible if Miranda described the Fifth Amendment right as opposed to a set of rules designed to protect that right. For example, in Harris v. New York, 401 U. S. 222, 224–226, the Court held that a statement obtained in violation of Miranda could be used to impeach the testimony of a defendant, even though an involuntary statement obtained in violation of the Fifth Amendment could not have been employed in this way. In Michigan v. Tucker, 417 U. S. 443, 450–452, n. 26, the Court held that the “fruits” of an un-Mirandized statement can be admitted. In doing so, the Court distinguished police conduct that “abridge[s] [a person’s] constitutional privilege against compulsory self-incrimination” from conduct that “depart[s] only from the prophylactic standards later laid down by this Court in Miranda to safeguard that privilege.” 417 U. S., at 445–446. Similarly, in Oregon v. Elstad, 470 U. S. 298, the Court, following the reasoning in Tucker, refused to exclude a signed confession and emphasized that an officer’s error “in administering the prophylactic Miranda procedures . . . should not breed the same irremediable consequences as police infringement of the Fifth Amendment itself.” Id., at 309.
While many of the Court’s decisions imposed limits on Miranda’s prophylactic rules, other decisions found that the balance of interests called for expansion. For example, in Doyle v. Ohio, 426 U. S. 610, the Court held that silence following a Miranda warning cannot be used to impeach. The Court acknowledged that Miranda warnings are “prophylactic,” 426 U. S., at 617, but it found that allowing the use of post-warning silence would undermine the warnings’ implicit promise that silence would not be used to convict. Id., at 618. Likewise, in Withrow v. Williams, 507 U. S. 680, the Court rejected an attempt to restrict Miranda’s application in collateral proceedings based on the reasoning in Stone v. Powell, 428 U. S. 465 (1976). Once again acknowledging that Miranda adopted prophylactic rules, the Court balanced the competing interests and found that the costs of adopting a Stone-like rule outweighed any benefits. In sum, the Court’s post-Miranda cases acknowledge the prophylactic nature of the Miranda rules and engage in cost-benefit analysis to define their scope.
(3) The Court’s decision in Dickerson v. United States, 530 U. S. 428, did not upset the firmly established prior understanding of Miranda as a prophylactic decision. Dickerson involved a federal statute, 18 U. S. C. §3501, that effectively overruled Miranda by making the admissibility of a statement given during custodial interrogation turn solely on whether it was made voluntarily. 530 U. S., at 431–432. The Court held that Congress could not abrogate Miranda by statute because Miranda was a “constitutional decision” that adopted a “constitutional rule,” 530 U. S., at 438–439, and the Court noted that these rules could not have been made applicable to the States if they did not have that status, see ibid. At the same time, the Court made it clear that it was not equating a violation of the Miranda rules with an outright Fifth Amendment violation. Instead, the Dickerson Court described the Miranda rules as “constitutionally based” with “constitutional underpinnings,” 530 U. S., at 440, and n. 5. Those formulations obviously avoided saying that a Miranda violation is the same as a violation of the Fifth Amendment right. Miranda was a “constitutional decision” and it adopted a “constitutional rule” in the sense that the decision was based on the Court’s judgment about what is required to safeguard that constitutional right. And when the Court adopts a constitutional prophylactic rule of this nature, Dickerson concluded, the rule has the status of a “La[w] of the United States” that is binding on the States under the Supremacy Clause (as Miranda implicitly held, since three of the four decisions it reversed came from state court, 384 U. S., at 491–494, 497–499), and the rule cannot be altered by ordinary legislation. Dickerson thus asserted a bold and controversial claim—that this Court has the authority to create constitutionally based prophylactic rules that bind both federal and state courts—but Dickerson cannot be understood any other way consistent with the Court’s prior decisions. Subsequent cases confirm that Dickerson did not upend the Court’s understanding of the Miranda rules as prophylactic. In sum, a violation of Miranda does not necessarily constitute a violation of the Constitution, and therefore such a violation does not constitute “the deprivation of [a] right . . . secured by the Constitution” for purposes of §1983.
(b) A §1983 claim may also be based on “the deprivation of any rights . . . secured by the . . . laws.” But the argument that Miranda rules constitute federal “law” that can provide the ground for a §1983 claim cannot succeed unless Tekoh can persuade the Court that this “law” should be expanded to include the right to sue for damages under §1983. “A judicially crafted” prophylactic rule should apply “only where its benefits outweigh its costs,” Shatzer, 559 U. S., at 106. Here, while the benefits of permitting the assertion of Miranda claims under §1983 would be slight, the costs would be substantial. For example, allowing a claim like Tekoh’s would disserve “judicial economy,” Parklane Hosiery Co. v. Shore, 439 U. S. 322, 326, by requiring a federal judge or jury to adjudicate a factual question (whether Tekoh was in custody when questioned) that had already been decided by a state court. Allowing §1983 suits based on Miranda claims could also present many procedural issues. Miranda and its progeny provide sufficient protection for the Fifth Amendment right against compelled self-incrimination.
985 F. 3d 713, reversed and remanded.
Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Gorsuch, Kavanaugh, and Barrett, JJ., joined. Kagan, J., filed a dissenting opinion, in which Breyer and Sotomayor, JJ., joined.