Vega v. Tekoh

142 S.Ct. 2095 (2022)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

P was working as a certified nursing assistant. A female patient accused him of sexually assaulting her. D, a Deputy Sheriff, responded. D questioned P at length in the hospital. P eventually provided a written statement apologizing for inappropriately touching the patient’s genitals. It is undisputed that D never informed P of his rights under Miranda. P was arrested and charged in California state court with unlawful sexual penetration. The judge held that Miranda had not been violated because P was not in custody when he provided the statement, but the trial resulted in a mistrial. P was retried. A second judge again denied his request to exclude the confession. This trial resulted in acquittal, and P then brought this action under 42 U. S. C. §1983 against D and several other defendants seeking damages for alleged violations of his constitutional rights, including his Fifth Amendment right against compelled self-incrimination. A jury returned a verdict in favor of D, but the judge concluded that he had given an improper jury instruction and thus granted a new trial. P asked the court to instruct the jury that it was required to find that D violated the Fifth Amendment right against compelled self-incrimination if it determined that he took a statement from P in violation of Miranda and that the statement was then improperly used against P at his criminal trial. The District Court declined. The jury was asked to decide whether P’s Fifth Amendment right had been violated. The court instructed the jury to determine, based on “the totality of all the surrounding circumstances,” whether P’s statement had been “improperly coerced or compelled,” and the court explained that “[a] confession is improperly coerced or compelled . . . if a police officer uses physical or psychological force or threats not permitted by law to undermine a person’s ability to exercise his or her free will.” The jury found in D’s favor, and P appealed. A Ninth Circuit panel reversed. It held that the “use of an un-Mirandized statement against a defendant in a criminal proceeding violates the Fifth Amendment and may support a §1983 claim” against the officer who obtained the statement. The Supreme Court granted certiorari.