Police officers cannot be prosecuted for violations of Miranda, Supreme Court rules

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WASHINGTON — The Supreme Court ruled Thursday that police officers could not be sued under federal civil rights law for failing to administer the familiar warning required by the court’s 1966 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 to seek execution by firing squad rather than lethal injection. The vote was 5-4, with Chief Justice John G. Roberts Jr. and Justice Brett M. Kavanaugh joining the three liberal court members to form a majority.

The case of the Miranda warnings illustrates the contested 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, #21-499, was brought by Terence B. Tekoh, a hospital attendant accused of sexually abusing an immobilized patient undergoing an emergency MRI. Mr. Tekoh was questioned at length by Carlos Vega, a deputy sheriff in Los Angeles.

The two men offered different accounts of the nature of the questioning, but it was undisputed that Mr. Vega had not given the Miranda warning, that Mr. Tekoh had signed a confession admitting to the assault, that a trial judge admitted his confession into evidence or that a jury acquitted him.

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Mr Tekoh then brought a lawsuit against Mr Vega under the Civil Rights Act, known as Section 1983, which allows citizens to sue state officials, including police officers, for violation of constitutional rights.

Judge Alito wrote that the remedy for a violation of the Miranda decision was the exclusion of the defendants’ statements in their criminal trials. The decision, he wrote, had failed to establish the type of constitutional right that could be vindicated 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 constitute a violation of the Constitution.”

“Miranda rests on a pragmatic judgment about what is necessary to end the violation at trial of the Fifth Amendment right against coerced self-incrimination,” Judge Alito wrote. “This prophylactic purpose is served by the suppression at trial 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 cause many problems.”

Chief Justice Roberts and Justices Kavanaugh, Clarence Thomas, Neil M. Gorsuch and Amy Coney Barrett joined the majority opinion.

Dissenting, Justice Elena Kagan wrote that the Supreme Court had repeatedly and emphatically stated that Miranda had established a constitutional right. This meant, she wrote, that officials who violated it were to be prosecuted under Section 1983.

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“Today, she writes, the court deprives individuals of the possibility of seeking redress for violations of the right recognized in Miranda. The majority observes that defendants can always request “the suppression at trial of statements obtained” in violation of Miranda’s procedures.

“But sometimes,” Judge Kagan continued, “such a statement will not be expunged. And sometimes, as a result, a defendant will be wrongfully convicted and spend years in prison. He may succeed, on appeal or habeas, in to quash the sentence. But then, what remedy does he have for all the harm he has suffered?

Justices Stephen G. Breyer and Sonia Sotomayor joined in Justice Kagan’s dissent.

Judge Kagan wrote the majority opinion in a second Civil Rights Act prosecution ruling, this one on whether a death row inmate in Georgia could sue officials there to find out how it was to be performed.

Supreme Court precedents require inmates who oppose methods of execution to identify an alternative. Mr. Nance proposed a firing squad, a method approved in four states but not in Georgia. He said Georgian officials could adapt one of these other states’ protocols.

The issue in Nance v. Ward, No. 21-439, was whether Mr. Nance could sue under the Civil Rights Act. Judge Kagan said yes.

“The prisoner does not challenge the death penalty itself; he takes the validity of that sentence as given,” she wrote. “And it provides the state with a real blueprint for carrying out the death penalty. If the detainee obtains the relief sought, it is because he has persuaded a court that the state could easily use his proposal to enforce it.

In dissent, Judge Barrett wrote that Mr Nance was required to file a habeas corpus challenge and could not use civil rights law because, in practice, he was seeking to frustrate his execution altogether.

“The court is looking too far down the road,” she wrote, suggesting Georgia’s potential adoption of the firing squad was speculation. “In my opinion, the consequence of the remedy which a prisoner seeks depends on the law of the State as it currently exists.”

Justices Thomas, Alito and Gorsuch joined in Justice Barrett’s dissent.

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