The Supreme Court’s decision in Vega v. Tekoh decidedly clarified Miranda rights violations cannot form the basis of a civil rights action for monetary damages.
In Vega, the Defendant Officer received a report regarding a potential sexual assault of a patient. The Officer went to the medical center where the alleged assault occurred and questioned Tekoh, a medical worker, regarding the complaints. However, the Officer never informed the worker of his Miranda rights, including the right to remain silent or to seek legal counsel. Tekoh eventually provided a written statement apologizing for inappropriately touching the patient’s genitals. This statement was subsequently used against Tekoh at his criminal trial. When the jury found Tekoh not guilty, he turned around and sued the Officer pursuant to 42 USC 1983, claiming that the Officer’s failure to give Tekoh his Miranda rights before questioning him constituted a violation of his civil rights.
Pursuant to 42 USC 1983, individuals may recover monetary damages for a violation of their civil rights. Prior to the Supreme Court’s holding in Vega, the circuit courts were split as to whether to permit claims for damages where an officer violates an individual’s Miranda rights. The United States Supreme Court clarified that a violation of Miranda does not create a cause of action for monetary relief in a subsequent civil action. Further, the appropriate arena to address a violation of Miranda rights is in the individual’s criminal trial rather than a civil rights suit. Thus, Miranda warnings are still required to protect an individual’s Fifth Amendment rights, but an officer cannot be held civilly liable for failing to provide the requisite Miranda warnings.
This decision was a relief to many law enforcement agencies and officials who regularly and routinely deal with Miranda rights and related issues.
The attorneys at Fishel Downey regularly advise law enforcement officials on civil rights litigation and liabilities. If you have a specific question or scenario, and would like assistance, contact one of the attorneys at Fishel Downey Albrecht & Riepenhoff LLP at 614-221-1216.