Supreme Court limited ability to enforce Miranda is right in a ruling Thursday that said suspects, not warned of their right to remain silent, cannot sue a police officer for damages under federal civil rights law, even if the evidence was ultimately used against them in their criminal case. process.
A court order will limit a person’s protection from self-incrimination by excluding the possibility of obtaining damages. It also means that failure to comply with a warning does not expose the law enforcement officer to potential civil harm. However, this will not affect the exclusion of such evidence in criminal proceedings.
The Court clarified that while Miranda’s warning protects a constitutional right, the warning itself is not a right that allows a civil suit to be filed.
“Today’s decision doesn’t get rid of Miranda’s right,” said Steve Wladek, a CNN Supreme Court analyst and professor at the University of Texas Law School. “But this makes it much more difficult to comply with it. Under this ruling, the only defense against a Miranda violation is to withhold testimony from a suspect who has not been properly advised of his right to remain silent. But if the case never goes to trial, or if the government never tries to use the statement, or if the statement is admitted despite the Miranda violation, then there will be no remedy for government misconduct.”
Judge Samuel Alito, joined by five other Republican-appointed justices, said that Miranda’s violation of the right “is not in itself a violation of the Fifth Amendment” and that “we see no justification for expanding Miranda to grant the right to sue.” “, in accordance with the relevant law.
Justice Elena Kagan, joined by other liberal judges, said the court’s decision makes it impossible for “individuals to seek remedies for violations of the rights recognized by Miranda.”
“The majority here, as elsewhere, damage the law by denying a remedy,” she added.
The case concerned Terence Teko, a hospital worker who was accused in 2014 of sexually assaulting an immobilized patient at a local hospital.
The question was not whether the defendant should have his Miranda rights read to him, but whether he could sue the officer for damages if he did not receive a Miranda warning regarding the evidence presented in the criminal trial. The lower courts were divided on this issue.
Carlos Vega, deputy sheriff of Los Angeles County, questioned Teco, although he was unable to read him his rights, as required by the 1966 case Miranda v. Arizona, where the court ruled that the defendant must be warned of the “right to remain silent.” “. Under this precedent, without Miranda’s warning, criminal courts are generally prohibited from accepting self-incriminating statements made while a defendant is in custody.
Tekoh eventually confessed to the crime, he was tried and acquitted – even after his confession was submitted to the court. He later sued the officer under a section of 1983 federal law that allows damages claims against a government official for violating constitutional rights.
The parties disagreed as to whether Vega used coercive methods to obtain an involuntary confession.
Vega’s lawyers stated that Tekoh’s statement was completely free and voluntary and technically he was not “in custody” at the time, while Tekoh’s lawyers claimed he was forced to confess in a windowless room.
Roman Martinez, Vega’s attorney, said that Teco could not sue because finding a Miranda violation did not establish a Fifth Amendment violation.
“Miranda is creating a procedural rule that prohibits prosecutors from making—and courts from admitting—certain rash statements in the main prosecution case in a criminal trial,” Martinez argued in court documents.
For Martinez, Miranda’s warning is a constitutional rule, not a right, and with that interpretation, the lawsuit cannot proceed. “Miranda does not forbid taking rash statements; it simply prohibits the subsequent recognition of such statements in court,” Martinez said.
He said the appeals court’s ruling in Tekoh’s favor would “cut off police departments across the country with an extraordinary burden of lawful and proper investigative work.” Any interaction with the police, according to Martinez, could lead to a private lawsuit, “even if the police officer acted perfectly legally.”
The Biden administration sided with Vega.
“Because the Miranda Rule is about the presentation of evidence in court, a suspect cannot sue a police officer under Section 1983 for violating this rule,” Solicitor General Elizabeth Prelogar said in court documents.
Teko’s lawyers alleged that Vega refused to accept Teko’s denials and that by “putting his hand on his firearm”, Vega threatened to report Teko and his family members to immigration. Teko has a green card and deportation could lead to persecution in Cameroon.
Paul Hoffman, a lawyer for Tekoh, said that Vega was “a central player in the chain of events leading up directly to the statement presented in court.”
This story has been supplemented by an additional report.
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