Police Officers Can’t Be Sued for Miranda Violations, Supreme Court Rules
WASHINGTON—The Supreme Court ruled on Thursday that police officers cannot be prosecuted under a federal civil rights law for failing to comply with the well-known warning required by the 1966 court ruling in Miranda v. Arizona† The vote was 6 to 3, with the judges dividing along ideological lines.
In a second case the court ruled that a death row inmate in Georgia could invoke the same civil rights law by attempting to be executed by firing squad rather than lethal injection. The vote was 5 to 4, with Chief Justice John G. Roberts Jr. and Judge Brett M. Kavanaugh joined the three Liberal members of the court to form a majority.
The Miranda warnings case illustrated the disputed status of the decision. Writing for the majority, Judge Samuel A. Alito Jr. said the ruling announced something less than a constitutional right.
The case, Vega v. Tekoh, No. 21-499, was brought by Terence B. Tekoh, a hospital worker charged with sexually abusing an immobilized patient undergoing an MRI scan. Mr. Tekoh was interrogated at length by Carlos Vega, a deputy sheriff in Los Angeles.
The two men gave different statements about the nature of the interrogation, but there was no question that Mr. Vega had failed to issue the Miranda warning, that Mr. Tekoh had signed a confession admitting to the attack, that a state judge had admitted his confession. admitted in evidence or that a jury acquitted him.
Mr. Tekoh subsequently filed a lawsuit against Mr. Vega under the Civil Rights Act known as: Section 1983that allows citizens to sue state officials, including police officers, for violations of constitutional rights.
Justice Alito wrote that the remedy for a violation of the Miranda decision was the exclusion of statements from the defendants during their criminal trial. The decision, he wrote, had not established the kind of constitutional right that could be justified by a lawsuit under Section 1983.
Justice Alito acknowledged that Miranda’s rights had constitutional roots. But he wrote that “a violation of Miranda does not necessarily mean a violation of the Constitution.”
“Miranda rests on a pragmatic judgment of what it takes to stop the violation at the fifth amendment forced self-incrimination trial,” Judge Alito wrote. “That prophylactic purpose is served by the suppression during the process of statements obtained in violation of Miranda.”
He added: “Allowing the victim of a Miranda violation to sue a police officer for damages under Section 1983 would have little additional deterrent value, and allowing such claims would create many problems.”
Chief Justice Roberts and Justices Kavanaugh, Clarence Thomas, Neil M. Gorsuch and Amy Coney Barrett joined the majority.
In contradiction, Judge Elena Kagan wrote that the Supreme Court had repeatedly and emphatically stated that Miranda had established a constitutional right. That meant, she wrote, that officials who violated it would be subject to lawsuits under Section 1983.
“Today,” she wrote, “the court deprives individuals of the opportunity to seek redress for violations of the law recognized in Miranda. The majority noted that defendants can still demand “the suppression of statements obtained in the process” that violate Miranda’s procedures.”
“But sometimes,” Judge Kagan continued, “such a statement will not be suppressed. And sometimes, as a result, a defendant is wrongly convicted and sentenced to years in prison. He can succeed in overturning the conviction on appeal or in habeas. But what remedy does he have for all the damage he has suffered?”
Judges Stephen G. Breyer and Sonia Sotomayor joined Judge Kagan’s disagreement.
Judge Kagan wrote the majority opinion in a second decision on lawsuits under the civil rights law, this one over whether a death row inmate in Georgia could sue officials there over how he would be executed.
The inmate, Michael Nance, argued that his constitutional right to be spared cruel and unusual punishments under the Eighth Amendment would be violated if he were put to death by lethal injection because his veins were damaged.
According to Supreme Court precedents, inmates who object to methods of execution must find an alternative. Mr. Nance suggested firing squad, a method approved in four states but not Georgia. He said officials in Georgia could modify any of those other states’ protocols.
The question in the case, Nance v. Ward, No. 21-439, was whether Mr. Nance could sue under the Civil Rights Act. Justice Kagan said yes.
“The prisoner does not challenge the death penalty itself; he takes the validity of that sentence as a given,” she wrote. “And he is giving the state a real blueprint for carrying out the death sentence. If the prisoner gets his requested exemption, it will be because he has convinced a court that the state could easily use his proposal to execute him.”
In contradiction, Judge Barrett wrote that Mr. Nance had to file a habeas corpus challenge and could not use the civil rights law because, in practice, he wanted to completely thwart his execution.
“The court is looking too far out,” she wrote, suggesting the Georgia firing squad’s possible adoption was speculation. “In my opinion, the consequence of the shelter a prisoner seeks depends on state law.” as it currently exists†
Judges Thomas, Alito and Gorsuch joined Judge Barrett’s disagreement.