Vega v. Tekoh
Issues
Can a person bring a claim for monetary damages under 42 U.S.C. § 1983 based upon a police officer’s failure to provide a Miranda warning?
This case asks the Supreme Court to decide whether a hospital employee, who was not given a Miranda warning by a deputy before he confessed to assaulting a patient, may sue the individual officer for monetary damages under 42 U.S.C. § 1983. Petitioner Deputy Carlos Vega contends that he did not violate Terence Tekoh’s Fifth Amendment rights because a Miranda violation is not a de facto constitutional violation. Thus, Vega asserts that Tekoh has failed to state a claim for relief under 42 U.S.C. § 1983. Respondent Terence Tekoh counters that Supreme Court precedent has established a constitutional requirement for police officers to issue Miranda warnings. Therefore, Tekoh argues a prosecutor’s introduction of a statement obtained in violation of Miranda establishes a constitutional violation redressable by 42 U.S.C. § 1983. The outcome of this case has heavy implications for public safety and the protection of constitutional rights.
Questions as Framed for the Court by the Parties
Whether a plaintiff may state a claim for relief against a law enforcement officer under 42 U.S.C. § 1983 based simply on an officer’s failure to provide the warnings prescribed in Miranda v. Arizona.
On March 14, 2014, a patient at Los Angeles County/USC Medical Center accused hospital orderly Terence Tekoh (“Tekoh”) of sexual assault. Brief for Petitioner, Carlos Vega at 5. Deputy Carlos Vega (“Vega”) responded to investigate. Tekoh v. Cnty.
Additional Resources
- Hunter Ransom, You Have the Right to Remain Silent... and a § 1983 Claim? An Un-Mirandized Defendant’s Plea for Damages, Mississippi College Law Review (Mar. 11, 2022).
- Lisa Soronen, Supreme Court to Decide Whether Failure to Mirandize Means Money Damages, National Conference of State Legislatures (Jan. 19, 2022).