Vega v. Tekoh, 2022 U.S. LEXIS 3053 (S. Ct. June 23, 2022) (Alito, J.) This case presents the question whether a plaintiff may sue a police officer under Rev. Stat. §1979, 42 U. S. C. §1983, based on the allegedly improper admission of an “un-Mirandized” statement in a criminal prosecution. 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 his place of employment and did not give him a Miranda warning. Tekoh was prosecuted, and his confession was admitted into evidence, but the jury returned a verdict of not guilty. Tekoh then sued Vega under §1983, and the United States Court of Appeals for the Ninth Circuit held that the use of Tekoh’s un-Mirandized statement provided a valid basis for a §1983 claim against Vega. We now reject this extension of our Miranda case law. If a Miranda violation were tantamount to a violation of the Fifth Amendment, our answer would of course be different. The Fifth Amendment, made applicable to the States by the Fourteenth Amendment, Malloy v. Hogan, 378 U. S. 1, 6, 84 S. Ct. 1489, 12 L. Ed. 2d 653 (1964), provides that “[n]o person . . . shall be compelled in any criminal case to be a witness against himself.” This Clause “permits a person to refuse to testify against himself at a criminal trial in which he is a defendant” and “also ‘privileges him not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings.’” Minnesota v. Murphy, 465 U. S. 420, 426, 104 S. Ct. 1136, 79 L. Ed. 2d 409 (1984) (quoting Lefkowitz v. Turley, 414 U. S. 70, 77, 94 S. Ct. 316, 38 L. Ed. 2d 274 (1973)). In addition, the right bars the introduction against a criminal defendant of out-of-court statements obtained by compulsion. See, e.g., Bram v. United States, 168 U. S. 532, 565, 18 S. Ct. 183, 42 L. Ed. 568 (1897); Miranda, 384 U. S., at 466, 86 S. Ct. 1602, 16 L. Ed. 2d 694; Michigan v. Tucker, 417 U. S. 433, 440-442, 94 S. Ct. 2357, 41 L. Ed. 2d 182 (1974). In Miranda, the Court concluded that additional procedural protections were necessary to prevent the violation of this important right when suspects who are in custody are interrogated by the police. To afford this protection, the Court required that custodial interrogation be preceded by the now-familiar warnings mentioned above, and it directed that statements obtained in violation of these new rules may not be used by the prosecution in its case-in-chief. 384 U. S., at 444, 479, 86 S. Ct. 1602, 16 L. Ed. 2d 694. In this case, the Ninth Circuit held—and Tekoh now argues, Brief for Respondent 20—that a violation of Miranda constitutes a violation of the Fifth Amendment right against compelled self-incrimination, but that is wrong. Miranda itself and our subsequent cases make clear that Miranda imposed a set of prophylactic rules. Those rules, to be sure, are “constitutionally based,” Dickerson, 530 U. S., at 440, 120 S. Ct. 2326, 147 L. Ed. 2d 405, but they are prophylactic rules nonetheless. Because a violation of Miranda is not itself a violation of the Fifth Amendment, and because we see no justification for expanding Miranda to confer a right to sue under §1983, the judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.
June 28th, 2022 by Rieders Travis in Civil Rights