Vega v. Tekoh | Case No. 21-499 | Date Argued: 4/20/2022 | Date Decided: 6/23/2022

Background: In Miranda v. Arizona, 384 U.S. 436 (1966), this Court announced a prophylactic rule protecting the Fifth Amendment right against self-incrimination. That rule generally prohibits criminal trial courts from admitting into evidence against a criminal defendant any self- incriminating statement made by that defendant while he was in custody, unless the defendant first received certain warnings spelled out in Miranda. The Civil Rights Act of 1871, 42 U.S.C. § 1983, provides a damages remedy for deprivations of any right secured by the Constitution and laws of the United States.

Question Presented: Whether a plaintiff may state a claim for relief against a law enforcement officer under Section 1983 based simply on an officer's failure to provide the warnings prescribed in Miranda.

Holding: A violation of the Miranda rules does not provide a basis for a §1983 claim.

Result: Judgment REVERSED and case REMANDED.

Voting Breakdown: 6-3. Justice Alito delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh and Barrett joined. Justice Kagan filed a dissenting opinion, in which Justices Breyer and Sotomayor joined.

Link to Opinion: Here.

Oral Advocates:

For Petitioner: Roman Martinez, Washington, D.C.; and Vivek Suri, Assistant to the Solicitor General, Department of Justice, Washington, D.C. (for United States, as amicus curiae.) For Respondent: Paul L. Hoffman, Hermosa Beach, Cal.