A recent U.S. Supreme Court decision may protect police officers from lawsuits regarding Miranda rights violations.
Under the court’s ruling, police officers who fail to warn suspects about their Miranda rights — commonly known as the right to remain silent — cannot be sued for damages under federal civil rights law.
The court ruled in favor of Los Angeles County Deputy Carlos Vega in the officer’s appeal of a lower court’s decision over whether the deputy violated hospital employee Terence Tekoh’s Fifth Amendment right to protection against self-incrimination.
Tekoh, who was charged with sexual assault back in 2014, had provided Vega at the time with a written confession before receiving his Miranda warnings from the officer.
Although the incriminating statements were included as evidence in the trial, Tekoh was later acquitted by the jury.
In a subsequent lawsuit against Vega for civil rights violations, Vega’s lawyers held that Tekoh was not in custody at the time he voluntarily confessed to police, and therefore, there was no violation.
Vega’s attorney, Roman Martinez, further explained that violations of police procedures are not necessarily tantamount to violations of constitutional rights.
“Miranda creates a procedural rule barring prosecutors from introducing — and courts from admitting — certain unwarned statements as a part of the prosecution’s case-in-chief at a criminal trial,” he explained.
Supreme Court justices ultimately weighed in on the issue, voting 6–3 in favor of Vega, arguing that Miranda warnings are intended to protect constitutional rights but are not in themselves a right that can be violated. Therefore, there are no grounds for a lawsuit.
“Miranda itself was clear on this point. Miranda did not hold that a violation of the rules it established necessarily constitutes a Fifth Amendment violation, and it is difficult to see how it could have held otherwise,” Justice Samuel Alito wrote in the Court’s opinion. “Instead, it only claimed that those rules were needed to safeguard that right during custodial interrogation,” he said.
The three dissenting votes came from liberal justices.
In their appeal to the Supreme Court, Vega’s attorneys added that the lower 9th Circuit Court’s decision would “saddle police departments nationwide with extraordinary burdens in connection with lawful and appropriate investigative work.” In addition, “virtually any police interaction with a criminal suspect” could leave police officers open to liability.
The outcome “confirms that Deputy Vega cannot be sued for his good-faith effort to investigate the alleged sexual assault of a defenseless hospital patient,” Martinez added.
In a dissenting opinion, Justice Elena Kegan argued that the 1966 trial, Miranda v. Arizona, established a precedent for the use of certain police procedures and that failing to follow such procedures would be a violation of the right they are meant to protect.
“Today, the court strips individuals of the ability to seek a remedy for violations of the right recognized in Miranda,” Kagan wrote.
However, Kagan clarified that even if defendants cannot sue officers for violating Miranda procedures, they can still seek “the suppression at trial of statements obtained” in violation of Miranda’s procedures.