## Facts

- A hospital patient accused Terence Tekoh, a hospital employee, of sexual assault.
- Deputy Carlos Vega investigated and questioned Tekoh at the hospital.
- Vega did not provide Miranda warnings before questioning or obtaining a written statement from Tekoh.
- Tekoh gave a written statement described as apologizing for inappropriate touching.
- California prosecuted Tekoh for unlawful sexual penetration; the unwarned statement was admitted at trial.
- A jury acquitted Tekoh.
- Tekoh then sued Vega under 42 U.S.C. § 1983, seeking damages based on the interrogation and the statement’s use at trial.
- A federal jury found for Vega, but the Ninth Circuit vacated and ordered a new trial, holding that use of an un-Mirandized statement in a criminal case violates the Fifth Amendment and can support § 1983 liability.

## Issues

1. Whether the use of an un-Mirandized statement in the prosecution’s case-in-chief is, by itself, a Fifth Amendment violation actionable for damages under 42 U.S.C. § 1983.
2. Whether Miranda’s warning requirement creates an individually enforceable constitutional “right” whose violation constitutes a “deprivation” remediable under § 1983.

## Decision

- The Supreme Court reversed the Ninth Circuit in a 6–3 decision.
- The Court held that a violation of Miranda rules does not provide a basis for a § 1983 claim.
- Failure to give Miranda warnings, even when followed by admission of the statement at trial, does not by itself establish a Fifth Amendment violation actionable under § 1983.
- The Court stated that Miranda remains enforceable through suppression of unwarned statements in the prosecution’s case-in-chief, but that remedy does not entail a damages action.

## Legal Principles

- Section 1983 requires a “deprivation” of a right secured by the Constitution or federal law; a breach of Miranda’s warning requirement, standing alone, is not such a deprivation.
- Miranda warnings are judicially created safeguards designed to protect the Fifth Amendment privilege against compelled self-incrimination; they are not identical to the constitutional privilege itself.
- The Fifth Amendment is violated by compelled self-incrimination; an unwarned statement may be voluntary and thus not compelled within the meaning of the Amendment.
- The principal remedy for a Miranda violation is exclusion of the unwarned statement from the prosecution’s case-in-chief, not civil damages.
- Recognition that Miranda is constitutionally based for purposes of invalidating contrary legislation does not mean every Miranda violation is automatically a Fifth Amendment violation for § 1983 purposes.

## Conclusion

The Court held that Miranda violations—failure to warn and the prosecution’s use of an unwarned statement in its case-in-chief—do not, without more, amount to a Fifth Amendment violation actionable for damages under 42 U.S.C. § 1983, leaving suppression as the primary remedy.


Vega v. Tekoh, 597 U.S. 134 (2022)