Defendant, who admitted in writing that he had been sexually harassed despite not reading his Miranda warnings, was ruled by the Supreme Court on Thursday 6-3 that he could not sue the officer even when the statement was used in court.
Miranda’s warnings, saying that the suspect has the right to remain silent, are traditionally read after arrest or before statements are made. Supreme Court Case Miranda v. Warnings came from Arizona.
“Miranda herself was clear on the matter. Miranda did not think that the violation of the rules she had established would necessarily be considered a violation of the Fifth Amendment and it is difficult to see how it would be handled,” Judge Samuel Alito wrote in court opinion. , In which he extensively mentions Miranda’s decision. “Instead, it only stated that those rules were necessary to protect that right during custodial interrogation,” he added.
Tekoh was a nursing assistant at a hospital where he sexually assaulted a patient. He did not advise Miranda about the warnings and after being questioned he admitted his actions and apologized.
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That statement was later accepted as evidence against him at trial. He pleaded not guilty, but filed a 1983 civil rights lawsuit against Los Angeles County Sheriff’s Deputy Carlos Vega for violating his constitutional rights without reading his rights before confession.
Alito cited several cases after Miranda in support of his argument that Miranda’s warnings were not a constitutional right but a “preventive” measure to protect a constitutional right. The court noted that Tekoh could still argue that the Miranda rules were “federal law” and could thus lead to a lawsuit.
“But anything more can be said about this argument, it will not be successful until Tekoh convinces us that this” law “should be extended to include the right to sue for damages under 6 §1983.”
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Alito argued that allowing such a claim was problematic, as a result of which the federal court “has already determined by the state court a factual question (whether Tekoh was in custody when questioned).” Alito wrote that this was “futile” and would cause “unnecessary conflict” between state and federal courts.
Justice Elena Kagan disagreed that she had met with judges Stephen Breyer and Sonia Sotomayor, arguing that Miranda had established a constitutional provision granting her a right, and therefore failing to issue Miranda warnings would infringe on that right.
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“Today, the court removes from individuals the ability to seek redress for violations of a right identified in Miranda,” Kagan wrote. The majority opinion is that she recognizes that the defendants still want ‘repression in the trial of statements obtained,’ violating Miranda’s policies, but in some cases, “such a statement will not be suppressed.”
As a result, Kagan writes, one of the defendants’ damages was compensated by §1983 lawsuits, but the court ruled that “the denial of compensation violates the right.”