Vega v. Tekoh

A Miranda violation is not itself a Fifth Amendment violation, and the use of an "un-Mirandized" statement does not provide a valid basis for a 42 U.S.C. § 1983 claim.

Respondent sued Petitioner pursuant to 42 U.S.C. § 1983 for having his “un-Mirandized” statement admitted in a criminal prosecution. At trial, the jury found in Petitioner’s favor. The Ninth Circuit reversed, holding that using an “un-Mirandized” statement against a defendant in a criminal proceeding violates the Fifth Amendment and provides a basis for § 1983 liability. The Court reversed and determined that Miranda and subsequent cases clearly imposed a set of constitutionally based prophylactic rules. Miranda did not hold that a violation of the rules constitute a Fifth Amendment violation because “un-Mirandized” suspects in custody may make self-incriminating statements without compulsion. Several post-Miranda cases have similarly avoided stating that Miranda violations are constitutional violations. Moreover, the costs of allowing Miranda claims under § 1983 outweighs the benefits because it would disserve judicial economy, produce unnecessary friction, and present procedural issues. Accordingly, a Miranda violation does not provide a basis for claim under § 1983. Reversed and remanded.