{"id":527,"date":"2022-07-03T13:36:55","date_gmt":"2022-07-03T13:36:55","guid":{"rendered":"https:\/\/courses.lumenlearning.com\/suny-monroe-law101\/?post_type=chapter&p=527"},"modified":"2026-04-19T15:28:52","modified_gmt":"2026-04-19T15:28:52","slug":"vega-v-tekoh","status":"publish","type":"chapter","link":"https:\/\/courses.lumenlearning.com\/suny-monroe-law101\/chapter\/vega-v-tekoh\/","title":{"raw":"VEGA v. TEKOH","rendered":"VEGA v. TEKOH"},"content":{"raw":"

Vega\u00a0v.\u00a0<\/em>Tekoh<\/strong><\/h2>\r\n

597 U.S. 134 (2022)<\/strong><\/h2>\r\n

(Case Syllabus had been edited by Author.)<\/p>\r\n

The case arose out of the interrogation of respondent, Terence Tekoh, by petitioner, Los Angeles County Sheriff\u2019s 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\u00a0Miranda<\/em>\u00a0v.\u00a0Arizona<\/em>,\u00a0384 U.\u00a0S. 436. Tekoh eventually provided a written statement apologizing for inappropriately touching the patient\u2019s 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\u00a042 U.\u00a0S.\u00a0C. \u00a71983, seeking damages for alleged violations of his constitutional rights. The Ninth Circuit held that the use of an un-Mirandized<\/em>\u00a0statement against a defendant in a criminal proceeding violates the\u00a0Fifth Amendment\u00a0and may support a \u00a71983 claim against the officer who obtained the statement.<\/p>\r\n

Held<\/em><\/strong>:<\/strong>\u00a0A violation of the\u00a0Miranda\u00a0<\/em>rules does not provide a basis for a \u00a71983 claim.<\/p>\r\n

\u2003\u2003(a)\u00a0Section 1983 provides a cause of action against any person acting under color of state law who \u201csubjects\u201d a person \u201cto the deprivation of any rights, privileges, or immunities secured by the Constitution and laws.\u201d Tekoh argues that a violation of\u00a0Miranda<\/em>\u00a0constitutes a violation of the\u00a0Fifth Amendment\u00a0right against compelled self-incrimination. That is wrong.<\/p>\r\n

\u2003\u2003(1)\u00a0In\u00a0Miranda<\/em>, the Court concluded that additional procedural protections were necessary to prevent the violation of the\u00a0Fifth Amendment\u00a0right against self-incrimination when suspects who are in custody are interrogated by the police.\u00a0Miranda\u00a0<\/em>imposed\u00a0<\/em>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.\u00a0S., at 444, 479.\u00a0Miranda<\/em>\u00a0did not hold that a violation of the rules it established necessarily constitute a\u00a0Fifth Amendment\u00a0violation. That makes sense, as an un-Mirandized<\/em>\u00a0suspect in custody may make self-incriminating statements without any hint of compulsion. \u2003The\u00a0Miranda<\/em>\u00a0Court stated that the Constitution did not itself require \u201cadherence to any particular solution for the inherent compulsions of the interrogation process\u201d and that its decision \u201cin no way create[d] a constitutional straitjacket.\u201d\u00a0Id<\/em>., at 467. Since\u00a0Miranda<\/em>, the Court has repeatedly described\u00a0Miranda<\/em>\u00a0rules as \u201cprophylactic.\u201d<\/p>\r\n

\u2003\u2003(2)\u00a0After\u00a0Miranda<\/em>, 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\u2019 scope. See\u00a0Maryland\u00a0<\/em>v.\u00a0Shatzer<\/em>,\u00a0559 U.\u00a0S. 98, 106. Some post-Miranda<\/em>\u00a0decisions found that the balance of interests justified restrictions that would not have been possible if\u00a0Miranda<\/em>\u00a0described the\u00a0Fifth Amendment\u00a0right as opposed to a set of rules designed to protect that right. For example, in\u00a0Harris\u00a0<\/em>v.\u00a0New York<\/em>,\u00a0401 U.\u00a0S. 222, 224\u2013226, the Court held that a statement obtained in violation of\u00a0Miranda<\/em>\u00a0could be used to impeach the testimony of a defendant, even though an involuntary statement obtained in violation of the\u00a0Fifth Amendment\u00a0could not have been employed in this way. In\u00a0Michigan<\/em>\u00a0v.\u00a0Tucker<\/em>,\u00a0417 U.\u00a0S. 443, 450\u2013452, n. 26, the Court held that the \u201cfruits\u201d of an un-Mirandized<\/em>\u00a0statement can be admitted. In doing so, the Court distinguished police conduct that \u201cabridge[s] [a person\u2019s] constitutional privilege against compulsory self-incrimination\u201d from conduct that \u201cdepart[s] only from the prophylactic standards later laid down by this Court in\u00a0Miranda<\/em>\u00a0to safeguard that privilege.\u201d 417 U.\u00a0S., at 445\u2013446. Similarly, in\u00a0Oregon\u00a0<\/em>v.\u00a0Elstad<\/em>,\u00a0470 U.\u00a0S. 298, the Court, following the reasoning in\u00a0Tucker<\/em>, refused to exclude a signed confession and emphasized that an officer\u2019s error \u201cin administering the prophylactic\u00a0Miranda<\/em>\u00a0procedures .\u00a0.\u00a0. should not breed the same irremediable consequences as police infringement of the\u00a0Fifth Amendment\u00a0itself.\u201d\u00a0Id<\/em>., at 309.<\/p>\r\n

\u2003\u2003While many of the Court\u2019s decisions imposed limits on\u00a0Miranda<\/em>\u2019s prophylactic rules, other decisions found that the balance of interests called for expansion. For example, in\u00a0Doyle\u00a0<\/em>v.\u00a0Ohio<\/em>,\u00a0426 U.\u00a0S. 610, the Court held that silence following a\u00a0Miranda<\/em>\u00a0warning cannot be used to impeach. The Court acknowledged that\u00a0Miranda<\/em>\u00a0warnings are \u201cprophylactic,\u201d 426 U.\u00a0S.,\u00a0<\/em>at 617, but it found that allowing the use of post-warning silence would undermine the warnings\u2019 implicit promise that silence would not be used to convict.\u00a0Id.,<\/em>\u00a0at 618. Likewise, in\u00a0Withrow\u00a0<\/em>v.\u00a0Williams<\/em>,\u00a0507 U.\u00a0S. 680, the Court rejected an attempt to restrict\u00a0Miranda<\/em>\u2019s application in collateral proceedings based on the reasoning in\u00a0Stone<\/em>\u00a0v.\u00a0Powell<\/em>,\u00a0428 U.\u00a0S. 465 (1976). Once again acknowledging that\u00a0Miranda<\/em>\u00a0adopted prophylactic rules, the Court balanced the competing interests and found that the costs of adopting a\u00a0Stone<\/em>-like rule outweighed any benefits. In sum, the Court\u2019s post-Miranda<\/em>\u00a0cases acknowledge the prophylactic nature of the\u00a0Miranda<\/em>\u00a0rules and engage in cost-benefit analysis to define their scope.<\/p>\r\n

\u2003\u2003(3)\u00a0The Court\u2019s decision in\u00a0Dickerson<\/em>\u00a0v.\u00a0United States<\/em>,\u00a0530 U.\u00a0S. 428, did not\u00a0<\/em>upset the firmly established prior understanding of\u00a0Miranda\u00a0<\/em>as a prophylactic decision.\u00a0Dickerson<\/em>\u00a0involved a federal statute,\u00a018 U.\u00a0S.\u00a0C. \u00a73501, that effectively overruled\u00a0Miranda<\/em>\u00a0by making the admissibility of a statement given during custodial interrogation turn solely on whether it was made voluntarily. 530 U.\u00a0S., at 431\u2013432. The Court held that Congress could not abrogate\u00a0Miranda<\/em>\u00a0by statute because\u00a0Miranda<\/em>\u00a0was a \u201cconstitutional decision\u201d that adopted a \u201cconstitutional rule,\u201d 530 U.\u00a0S., at 438\u2013439, and the Court noted that these rules could not have been made applicable to the States if they did not have that status, see\u00a0ibid<\/em>. At the same time, the Court made it clear that it was not equating a violation of the\u00a0Miranda\u00a0<\/em>rules with an outright\u00a0Fifth Amendment\u00a0violation. Instead, the\u00a0Dickerson<\/em>\u00a0Court described the\u00a0Miranda<\/em>\u00a0rules as \u201cconstitutionally based\u201d with \u201cconstitutional underpinnings,\u201d 530 U.\u00a0S.,\u00a0<\/em>at 440, and n.\u00a05. Those formulations obviously avoided saying that a\u00a0Miranda<\/em>\u00a0violation is the same as a violation of the\u00a0Fifth Amendment\u00a0right.\u00a0Miranda<\/em>\u00a0was a \u201cconstitutional decision\u201d and it adopted a \u201cconstitutional rule\u201d in the sense that the decision was based on the Court\u2019s judgment about what is required to safeguard that constitutional right. And when the Court adopts a constitutional prophylactic rule of this nature,\u00a0Dickerson<\/em>\u00a0concluded, the rule has the status of a \u201cLa[w] of the United States\u201d that is binding on the States under the Supremacy Clause (as\u00a0Miranda<\/em>\u00a0implicitly held, since three of the four decisions it reversed came from state court, 384 U.\u00a0S., at 491\u2013494, 497\u2013499), and the rule cannot be altered by ordinary legislation.\u00a0Dickerson<\/em>\u00a0thus asserted a bold and controversial claim\u2014that this Court has the authority to create constitutionally based prophylactic rules that bind both federal and state courts\u2014but\u00a0Dickerson<\/em>\u00a0cannot be understood any other way consistent with the Court\u2019s prior decisions. Subsequent cases confirm that\u00a0Dickerson<\/em>\u00a0did not upend the Court\u2019s understanding of the\u00a0Miranda<\/em>\u00a0rules as prophylactic. In sum, a violation of\u00a0Miranda<\/em>\u00a0does not necessarily constitute a violation of the Constitution, and therefore such a violation does not constitute \u201cthe deprivation of [a] right .\u00a0.\u00a0. secured by the Constitution\u201d for purposes of \u00a71983.<\/p>\r\n

\u2003\u2003(b)\u00a0A \u00a71983 claim may also be based on \u201cthe deprivation of any rights .\u00a0.\u00a0. secured by the .\u00a0.\u00a0.\u00a0laws<\/em>.\u201d But the argument that\u00a0Miranda<\/em>\u00a0rules constitute federal \u201claw\u201d that can provide the ground for a \u00a71983 claim cannot succeed unless Tekoh can persuade the Court that this \u201claw\u201d should be expanded to include the right to sue for damages under \u00a71983. \u201cA judicially crafted\u201d prophylactic rule should apply \u201conly where its benefits outweigh its costs,\u201d\u00a0Shatzer<\/em>, 559 U.\u00a0S., at 106. Here, while the benefits of permitting the assertion of\u00a0Miranda\u00a0<\/em>claims under \u00a71983 would be slight, the costs would be substantial. For example, allowing a claim like Tekoh\u2019s would disserve \u201cjudicial economy,\u201d\u00a0Parklane Hosiery Co<\/em>. v.\u00a0Shore<\/em>,\u00a0439 U.\u00a0S. 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 \u00a71983 suits based on\u00a0Miranda<\/em>\u00a0claims could also present many procedural issues.\u00a0Miranda\u00a0<\/em>and its progeny provide sufficient protection for the\u00a0Fifth Amendment\u00a0right against compelled self-incrimination.<\/p>\r\n985 F.\u00a03d 713, reversed and remanded.\r\n\r\nAlito, J., delivered the opinion of the Court, in which\u00a0Roberts, C.\u00a0J., and\u00a0Thomas, Gorsuch, Kavanaugh, and\u00a0Barrett, JJ., joined.\u00a0Kagan, J.,\u00a0filed a dissenting opinion, in which\u00a0Breyer\u00a0and\u00a0Sotomayor, JJ., joined.\r\n\r\n ","rendered":"

Vega\u00a0v.\u00a0<\/em>Tekoh<\/strong><\/h2>\n

597 U.S. 134 (2022)<\/strong><\/h2>\n

(Case Syllabus had been edited by Author.)<\/p>\n

The case arose out of the interrogation of respondent, Terence Tekoh, by petitioner, Los Angeles County Sheriff\u2019s 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\u00a0Miranda<\/em>\u00a0v.\u00a0Arizona<\/em>,\u00a0384 U.\u00a0S. 436. Tekoh eventually provided a written statement apologizing for inappropriately touching the patient\u2019s 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\u00a042 U.\u00a0S.\u00a0C. \u00a71983, seeking damages for alleged violations of his constitutional rights. The Ninth Circuit held that the use of an un-Mirandized<\/em>\u00a0statement against a defendant in a criminal proceeding violates the\u00a0Fifth Amendment\u00a0and may support a \u00a71983 claim against the officer who obtained the statement.<\/p>\n

Held<\/em><\/strong>:<\/strong>\u00a0A violation of the\u00a0Miranda\u00a0<\/em>rules does not provide a basis for a \u00a71983 claim.<\/p>\n

\u2003\u2003(a)\u00a0Section 1983 provides a cause of action against any person acting under color of state law who \u201csubjects\u201d a person \u201cto the deprivation of any rights, privileges, or immunities secured by the Constitution and laws.\u201d Tekoh argues that a violation of\u00a0Miranda<\/em>\u00a0constitutes a violation of the\u00a0Fifth Amendment\u00a0right against compelled self-incrimination. That is wrong.<\/p>\n

\u2003\u2003(1)\u00a0In\u00a0Miranda<\/em>, the Court concluded that additional procedural protections were necessary to prevent the violation of the\u00a0Fifth Amendment\u00a0right against self-incrimination when suspects who are in custody are interrogated by the police.\u00a0Miranda\u00a0<\/em>imposed\u00a0<\/em>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.\u00a0S., at 444, 479.\u00a0Miranda<\/em>\u00a0did not hold that a violation of the rules it established necessarily constitute a\u00a0Fifth Amendment\u00a0violation. That makes sense, as an un-Mirandized<\/em>\u00a0suspect in custody may make self-incriminating statements without any hint of compulsion. \u2003The\u00a0Miranda<\/em>\u00a0Court stated that the Constitution did not itself require \u201cadherence to any particular solution for the inherent compulsions of the interrogation process\u201d and that its decision \u201cin no way create[d] a constitutional straitjacket.\u201d\u00a0Id<\/em>., at 467. Since\u00a0Miranda<\/em>, the Court has repeatedly described\u00a0Miranda<\/em>\u00a0rules as \u201cprophylactic.\u201d<\/p>\n

\u2003\u2003(2)\u00a0After\u00a0Miranda<\/em>, 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\u2019 scope. See\u00a0Maryland\u00a0<\/em>v.\u00a0Shatzer<\/em>,\u00a0559 U.\u00a0S. 98, 106. Some post-Miranda<\/em>\u00a0decisions found that the balance of interests justified restrictions that would not have been possible if\u00a0Miranda<\/em>\u00a0described the\u00a0Fifth Amendment\u00a0right as opposed to a set of rules designed to protect that right. For example, in\u00a0Harris\u00a0<\/em>v.\u00a0New York<\/em>,\u00a0401 U.\u00a0S. 222, 224\u2013226, the Court held that a statement obtained in violation of\u00a0Miranda<\/em>\u00a0could be used to impeach the testimony of a defendant, even though an involuntary statement obtained in violation of the\u00a0Fifth Amendment\u00a0could not have been employed in this way. In\u00a0Michigan<\/em>\u00a0v.\u00a0Tucker<\/em>,\u00a0417 U.\u00a0S. 443, 450\u2013452, n. 26, the Court held that the \u201cfruits\u201d of an un-Mirandized<\/em>\u00a0statement can be admitted. In doing so, the Court distinguished police conduct that \u201cabridge[s] [a person\u2019s] constitutional privilege against compulsory self-incrimination\u201d from conduct that \u201cdepart[s] only from the prophylactic standards later laid down by this Court in\u00a0Miranda<\/em>\u00a0to safeguard that privilege.\u201d 417 U.\u00a0S., at 445\u2013446. Similarly, in\u00a0Oregon\u00a0<\/em>v.\u00a0Elstad<\/em>,\u00a0470 U.\u00a0S. 298, the Court, following the reasoning in\u00a0Tucker<\/em>, refused to exclude a signed confession and emphasized that an officer\u2019s error \u201cin administering the prophylactic\u00a0Miranda<\/em>\u00a0procedures .\u00a0.\u00a0. should not breed the same irremediable consequences as police infringement of the\u00a0Fifth Amendment\u00a0itself.\u201d\u00a0Id<\/em>., at 309.<\/p>\n

\u2003\u2003While many of the Court\u2019s decisions imposed limits on\u00a0Miranda<\/em>\u2019s prophylactic rules, other decisions found that the balance of interests called for expansion. For example, in\u00a0Doyle\u00a0<\/em>v.\u00a0Ohio<\/em>,\u00a0426 U.\u00a0S. 610, the Court held that silence following a\u00a0Miranda<\/em>\u00a0warning cannot be used to impeach. The Court acknowledged that\u00a0Miranda<\/em>\u00a0warnings are \u201cprophylactic,\u201d 426 U.\u00a0S.,\u00a0<\/em>at 617, but it found that allowing the use of post-warning silence would undermine the warnings\u2019 implicit promise that silence would not be used to convict.\u00a0Id.,<\/em>\u00a0at 618. Likewise, in\u00a0Withrow\u00a0<\/em>v.\u00a0Williams<\/em>,\u00a0507 U.\u00a0S. 680, the Court rejected an attempt to restrict\u00a0Miranda<\/em>\u2019s application in collateral proceedings based on the reasoning in\u00a0Stone<\/em>\u00a0v.\u00a0Powell<\/em>,\u00a0428 U.\u00a0S. 465 (1976). Once again acknowledging that\u00a0Miranda<\/em>\u00a0adopted prophylactic rules, the Court balanced the competing interests and found that the costs of adopting a\u00a0Stone<\/em>-like rule outweighed any benefits. In sum, the Court\u2019s post-Miranda<\/em>\u00a0cases acknowledge the prophylactic nature of the\u00a0Miranda<\/em>\u00a0rules and engage in cost-benefit analysis to define their scope.<\/p>\n

\u2003\u2003(3)\u00a0The Court\u2019s decision in\u00a0Dickerson<\/em>\u00a0v.\u00a0United States<\/em>,\u00a0530 U.\u00a0S. 428, did not\u00a0<\/em>upset the firmly established prior understanding of\u00a0Miranda\u00a0<\/em>as a prophylactic decision.\u00a0Dickerson<\/em>\u00a0involved a federal statute,\u00a018 U.\u00a0S.\u00a0C. \u00a73501, that effectively overruled\u00a0Miranda<\/em>\u00a0by making the admissibility of a statement given during custodial interrogation turn solely on whether it was made voluntarily. 530 U.\u00a0S., at 431\u2013432. The Court held that Congress could not abrogate\u00a0Miranda<\/em>\u00a0by statute because\u00a0Miranda<\/em>\u00a0was a \u201cconstitutional decision\u201d that adopted a \u201cconstitutional rule,\u201d 530 U.\u00a0S., at 438\u2013439, and the Court noted that these rules could not have been made applicable to the States if they did not have that status, see\u00a0ibid<\/em>. At the same time, the Court made it clear that it was not equating a violation of the\u00a0Miranda\u00a0<\/em>rules with an outright\u00a0Fifth Amendment\u00a0violation. Instead, the\u00a0Dickerson<\/em>\u00a0Court described the\u00a0Miranda<\/em>\u00a0rules as \u201cconstitutionally based\u201d with \u201cconstitutional underpinnings,\u201d 530 U.\u00a0S.,\u00a0<\/em>at 440, and n.\u00a05. Those formulations obviously avoided saying that a\u00a0Miranda<\/em>\u00a0violation is the same as a violation of the\u00a0Fifth Amendment\u00a0right.\u00a0Miranda<\/em>\u00a0was a \u201cconstitutional decision\u201d and it adopted a \u201cconstitutional rule\u201d in the sense that the decision was based on the Court\u2019s judgment about what is required to safeguard that constitutional right. And when the Court adopts a constitutional prophylactic rule of this nature,\u00a0Dickerson<\/em>\u00a0concluded, the rule has the status of a \u201cLa[w] of the United States\u201d that is binding on the States under the Supremacy Clause (as\u00a0Miranda<\/em>\u00a0implicitly held, since three of the four decisions it reversed came from state court, 384 U.\u00a0S., at 491\u2013494, 497\u2013499), and the rule cannot be altered by ordinary legislation.\u00a0Dickerson<\/em>\u00a0thus asserted a bold and controversial claim\u2014that this Court has the authority to create constitutionally based prophylactic rules that bind both federal and state courts\u2014but\u00a0Dickerson<\/em>\u00a0cannot be understood any other way consistent with the Court\u2019s prior decisions. Subsequent cases confirm that\u00a0Dickerson<\/em>\u00a0did not upend the Court\u2019s understanding of the\u00a0Miranda<\/em>\u00a0rules as prophylactic. In sum, a violation of\u00a0Miranda<\/em>\u00a0does not necessarily constitute a violation of the Constitution, and therefore such a violation does not constitute \u201cthe deprivation of [a] right .\u00a0.\u00a0. secured by the Constitution\u201d for purposes of \u00a71983.<\/p>\n

\u2003\u2003(b)\u00a0A \u00a71983 claim may also be based on \u201cthe deprivation of any rights .\u00a0.\u00a0. secured by the .\u00a0.\u00a0.\u00a0laws<\/em>.\u201d But the argument that\u00a0Miranda<\/em>\u00a0rules constitute federal \u201claw\u201d that can provide the ground for a \u00a71983 claim cannot succeed unless Tekoh can persuade the Court that this \u201claw\u201d should be expanded to include the right to sue for damages under \u00a71983. \u201cA judicially crafted\u201d prophylactic rule should apply \u201conly where its benefits outweigh its costs,\u201d\u00a0Shatzer<\/em>, 559 U.\u00a0S., at 106. Here, while the benefits of permitting the assertion of\u00a0Miranda\u00a0<\/em>claims under \u00a71983 would be slight, the costs would be substantial. For example, allowing a claim like Tekoh\u2019s would disserve \u201cjudicial economy,\u201d\u00a0Parklane Hosiery Co<\/em>. v.\u00a0Shore<\/em>,\u00a0439 U.\u00a0S. 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 \u00a71983 suits based on\u00a0Miranda<\/em>\u00a0claims could also present many procedural issues.\u00a0Miranda\u00a0<\/em>and its progeny provide sufficient protection for the\u00a0Fifth Amendment\u00a0right against compelled self-incrimination.<\/p>\n

985 F.\u00a03d 713, reversed and remanded.<\/p>\n

Alito, J., delivered the opinion of the Court, in which\u00a0Roberts, C.\u00a0J., and\u00a0Thomas, Gorsuch, Kavanaugh, and\u00a0Barrett, JJ., joined.\u00a0Kagan, J.,\u00a0filed a dissenting opinion, in which\u00a0Breyer\u00a0and\u00a0Sotomayor, JJ., joined.<\/p>\n

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