Recent Supreme Court Rulings: Vega v. Tekoh

Terence Tekoh worked as a patient transporter for a hospital in Los Angeles. A patient accused him of sexual assault. The Los Angeles Police Department, upon receiving the report, sent Deputy Carlos Vega to the hospital to interview Tekoh. Deputy Vega took a statement from Tekoh without advising Tekoh of his rights pursuant to Miranda v. Arizona.

Tekoh was acquitted after trial and filed a lawsuit against Vega for violating his Fifth Amendment right against self-incrimination. A jury found in favor of Vega in the civil trial. Tekoh appealed and the Ninth Circuit vacated the decision and remanded for a new trial.

The US Supreme Court considered the question:

Is the use of an un-Mirandized statement against a defendant in a criminal case sufficient support a 42 U.S.C. § 1983 action?

Source: Oyez.org.

The Supreme Court held on June 22, 2022, that the use of an un-Mirandized statement against a defendant in a criminal case is not sufficient to support a cause of action under 42 U.S.C. §1983. A defendant may not sue an officer in civil court for failing to advise him of his Miranda rights; however, the statement is still subject to suppression in the criminal proceeding against him.