Justia Opinion Summary and Annotations

Los Angeles County 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 Miranda rights. Tekoh eventually provided a written statement and 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. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceeding violated the Fifth Amendment and could support a section 1983 claim.

The Supreme Court reversed. A violation of the Miranda rules does not provide a basis for a section 1983 claim. In Miranda, the Court concluded that additional procedural protections were necessary to prevent the violation of the Fifth Amendment right against self-incrimination. Miranda did not hold that a violation of the rules it established necessarily constitute a Fifth Amendment violation. The Miranda rules have been described as “constitutionally based” with “constitutional underpinnings,” but a Miranda violation is not the same as a violation of the Fifth Amendment right.

Miranda warnings are “prophylactic,” and can require balancing competing interests. A judicially crafted prophylactic rule should apply only where its benefits outweigh its costs. While the benefits of permitting the assertion of Miranda claims under section 1983 would be slight, the costs would be substantial.

Annotation

Primary Holding

A violation of the Miranda rules does not provide a basis for a section 1983 Fifth Amendment claim.