A civil-rights lawsuit against an officer who failed to give Miranda warnings led the Supreme Court to examine the nature of its landmark ruling that, as Justice Elena Kagan said, is central to people’s understanding of the law.
Lawyers sparred at argument on Wednesday over how to classify Miranda and subsequent precedents, namely whether they provide a constitutional right.
How the justices answer the question will affect whether people can sue officers who fail to give those self-incrimination warnings and, in the process, the court can issue its latest pronouncement on the 1966 ruling.
Miranda v. Arizona was one of several 1960s criminal-procedure cases that conservatives have decried as unfounded. But conservative Chief Justice William Rehnquist authored 2000’s Dickerson v. United States, which upheld Miranda.
Though what exactly Rehnquist was up to in Dickerson was subject to debate at Wednesday’s argument.
Kagan said Rehnquist “understood that Miranda had come to mean something extremely important in the way people understood the law and the way people understood the Constitution,” and that undermining that ruling could undermine the court.
Los Angeles deputy Carlos Vega’s lawyer, Roman Martinez, rejected the notion that a ruling for his client would damage that precedent.
But he said Miranda “is a judicially crafted prophylactic rule, and the violation of such a rule doesn’t violate the constitutional rights of any person.” He pointed to a subsequent case, 2003’s Chavez v. Martinez, where a plurality of the court including Rehnquist endorsed that view.
Yet Justice Clarence Thomas, who wrote that plurality opinion, noted that he “couldn’t get a majority,” so he doesn’t “know how much that does for you.”
Chief Justice John Roberts said people couldn’t keep unwarned confessions out of evidence if it wasn’t for the Constitution. “So why isn’t that right one secured by the Constitution?” he asked Martinez.
But Roberts, who clerked for Rehnquist, also told Paul Hoffman, the lawyer for the man who sued Vega, that Rehnquist was “somebody careful with his words, he didn’t say Miranda is in the Constitution. He talked about constitutional underpinnings, constitutional basis.”
Likewise, Justice Amy Coney Barrett observed that Dickerson “didn’t ever use the word ‘constitutional’ right. It seemed very carefully worded to say constitutional rule or constitutionally required.”
Terence Tekoh sued Vega after a criminal jury acquitted Tekoh of sexually assaulting a patient at a Los Angeles medical center where he worked in 2014. Vega failed to give Miranda warnings for the statement that was used against him at trial that Tekoh says was a coerced false confession.
In his civil case, the trial court said Miranda violations alone aren’t enough to sue officers. The U.S. Court of Appeals for the Ninth Circuit reversed the trial court and Vega appealed to the justices.
A decision is expected by late June.
The case is Vega v. Tekoh, U.S., 21-499.