No. 21-499 – Argued April 20, 2022 – Decided June 23, 2022
The Court addressed the question of whether a police officer’s failure to give Miranda warnings was, by itself, enough to support a section 1983 civil rights claim for money damages against an individual police officer. The Court reversed the Court of Appeals for the Ninth Circuit, instead holding that the mere use of a person’s un-Mirandized statement does not provide a valid basis for a 1983 civil rights claim against a police officer.
Case Background
In 2014, police investigated a report of sexual assault allegedly committed by a certified nursing assistant against a hospital patient. Police responded to the medical center and interviewed the suspect. Police did not give Miranda warnings during the interview, but did obtain a written statement from the suspect.
Criminal charges were filed in state court. The trial court ruled that the written statement was admissible as evidence against the defendant. Nevertheless, a jury ultimately acquitted the defendant of the alleged crime.
Following his acquittal, the defendant filed a civil rights claim in federal court under 42 U.S.C 1983. At trial, the District Court ruled that failure to give the warnings required under Miranda did not, by itself, constitute a violation of Fifth Amendment Rights. Instead, the District Court instructed the jury that they must consider “the totality of all the surrounding circumstances” and determine whether the statement had been “improperly coerced or compelled.” The jury found in favor of the police officer.
On appeal, the Court of Appeals for the Ninth Circuit reversed the District Court and held that the “use of an un-Mirandized statement against a defendant in a criminal proceeding violates the Fifth Amendment and may support a [section] 1983 claim” against the individual police officer who obtained the statement.
Miranda and the Fifth Amendment
In reaching its decision, the Ninth Circuit relied on the United States Supreme Court’s decision in Dickerson v. United States, 430 U.S. 428 (2000). The Ninth Circuit read that decision as being “clear that the right of a criminal defendant against having an un-Mirandized statement introduced in the prosecution’s case in chief is indeed a right secured by the Constitution,” and remanded the case to the District Court for a new trial. A petition for a writ of certiorari was filed and granted by the Supreme Court.
Section 1983 provides for a cause of action against an individual who, acting under color of state law, subjects a person or causes a person to be subjected to “the deprivation of any rights, privileges, or immunities secured by the Constitution and laws.”
In this case, it was uncontested that the police officer did not give Miranda warnings. At issue, instead, was the question of whether that failure to give those warnings was itself a deprivation of “any rights privileges, or immunities secured by the Constitution and laws.”
In reversing the decision of the Ninth Circuit, the majority opinion emphasized the Miranda warnings serve as a prophylactic measure intended to safeguard the privilege against compelled self-incrimination under the Fifth Amendment. The warnings are not directly required by the Constitution, but are instead a judicially-imposed requirement intended to prevent a violation of Constitutional rights.
Miranda Warnings in Criminal Cases
In addressing a motion to suppress for violation of the Miranda requirements, a trial court will first look at the context in which the incriminating statement was given. Miranda warnings are not required in every situation where police officers may interview or interact with suspects or other individuals. Instead, the courts require only that the Miranda warnings be given
Under Miranda and its progeny, courts in criminal cases employ a presumption that an un-Mirandized self-incriminating statement made in the context of a custodial interrogation is compelled or coerced, even in the absence of clear evidence of actual compulsion or coercion. However, if Miranda warnings are given, then the burden shifts to the criminal defendant to show that the statement was improperly coerced or compelled.
In a criminal prosecution, the court should exclude an incriminating statement if that statement was obtained either in violation of the prophylactic rules set out in Miranda, or if the incriminating statement is the result of police conduct that constitutes actual improper coercion or compulsion.
Miranda Warnings in Civil Rights Cases
Under the Supreme Court’s ruling in Vega v. Tekoh, failing to give Miranda warnings is not alone sufficient to support a 1983 civil rights claim. A police officer’s failure to comply with the requirements of Miranda is a factor that may be considered by a jury in determining whether police acted improperly by obtaining an incriminating statement using actual coercion or compulsion. But in order to recover money damages in a 1983 civil rights action, a plaintiff must prove that the statement was actually compelled or coerced.
The Takeaway
The Supreme Court’s decision in Vega v. Tekoh should not be interpreted as eliminating or reducing the Fifth Amendment rights of a criminal defendant or the Fifth Amendment rights of any other person. Instead, the Vega decision should be understood as clarifying that a violation of Miranda’s prophylactic rules does not give rise to a claim for money damages against an individual police officer under 42 U.S.C. 1983. Such a claim requires evidence that the police officer actually engaged compulsive or coercive conduct that resulted in the making of an incriminating statement by a suspect.
