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In the United States, before law enforcement officers interrogate suspects in custody, they must inform the suspects of their rights with a notification called a Miranda warning. It notifies suspects that they have the right to remain silent and that whatever they say can and will be used against them in court. Furthermore, the warning informs suspects of their right to hire an attorney or to be provided with one if they cannot afford to hire one.
“For years now, this Miranda warning has been a shield to suspects against self-incrimination,” says Andrew Lindsey. Miranda warning, established in the 1960s, came into the national spotlight again following the supreme court ruling on June 23rd, 2022. The Supreme Court ruling shields officers from being sued for violating the Miranda right.
Reason Behind the Establishment of the Miranda Right
Miranda rights, established in a landmark supreme court case called Miranda v. Arizona in 1966, aims to prevent self-incrimination. A Miranda warning aimed to ensure suspects know their rights before making any statements to law enforcement officers. The American Civil Liberties Union (ACLU) initiated the landmark supreme court case.
The ACLU filed the suit on behalf of Ernesto Miranda, a man from Arizona convicted of rape and kidnapping based on an involuntary confession. Furthermore, the legal system created the Miranda right when there were allegations against police for using coercive tactics to extract confessions from suspects.
Since its enactment, reading the Miranda rights has become a mandatory law enforcement practice in the U.S. However, Miranda rights are not limited to the United States. According to the Federation of American Scientists (FAS), 108 countries and jurisdictions have some form of Miranda warning in their legal systems.
The Case That Led to the Decision Not to Sue Police for Violating Miranda Rights
The case arose from the interrogation of a suspect by a Los Angeles police officer in 2014. A nursing assistant, Terence Tekoh, was accused of sexually assaulting a female patient at a hospital. Deputy Sheriff Carlos Vega interrogated Tekoh without reading the Miranda warning and obtained a written apology from him.
Consequently, the court convicted Terence Tekoh of sexual assault based on the statement. However, after being acquitted by a jury, Tekoh sued Carlos Vega and others for damages under Section 1983 of the Civil Rights Act. The act allows citizens to sue state officials (police officers and other government workers) for deprivation or violation of their constitutional rights and privileges.
The case raised a question that the Supreme Court had not responded to before. The question is whether a defendant can sue a police officer for violating their constitutional rights by failing to give them a Miranda warning.
The Supreme Court Ruling on the Case
On June 23rd, the Supreme Court responded to whether a defendant can sue an officer for violating the Miranda right. The Supreme Court ruled that officers who fail to give criminal suspects Miranda warnings before questioning are immune to a lawsuit for their omissions.
The justices ruled 6-3 in support of the Deputy Sheriff, who failed to read a Miranda warning to nursing assistant Terence Tekoh. In his majority opinion, Justice Samuel Alito stated that a violation of Miranda does not constitute a violation of the Fifth Amendment.
Furthermore, he stated that the majority sees no reason to expand Miranda to permit a right to sue under Section 1983 of the federal law. In essence, the justices decided that receiving Miranda warnings is not a constitutionally protected right but a set of rules established to protect the Fifth Amendment. Therefore the court classification means that a violation of Miranda warnings is not grounds for filing a lawsuit under Section 1983.
Are Officers Still Required to Read the Miranda Right?
The Supreme Court decision limits the ability of citizens to seek compensation for damages if Miranda rights are not read to them before questioning. But, the law enforcement officers are still required to read the Miranda rights to the suspects before interrogating them. While the decision protects law enforcement officers from civil lawsuits for Miranda rights violations, it will also protect citizens in a certain way.
The court also ruled that gathering suspect comments before they receive the Miranda warnings nullifies using the statement to incriminate them during a trial. According to the court, this provision offers a complete and sufficient remedy for violations of the Miranda right by law enforcement officers. Thus, if a suspect makes a statement without receiving the Miranda warning from officers, the evidence gathered may be thrown out of court.
The exclusionary rule governs this. This exclusionary rule prohibits the court from using evidence gathered from individuals while violating their constitutional rights. But, if officers read Miranda rights and the suspect still makes statements, the evidence becomes valid and can be used by the prosecution or defense.
The Criticism Against the Supreme Court Decision
In disagreement with the court ruling, Justice Elena Kagan wrote a critical dissent, joined by fellow Justice Sonia Sotomayor and Justice Stephen Breyer. According to Justice Kagan, the court deprives individuals of the ability to seek remedy for violations of the Miranda rights. However, the majority points out that defendants may still seek suppression (exclusion) of statements obtained in violation of Miranda procedures at trial.
In response to this, Kagan states that such a statement will not be suppressed and may lead to the defendant being wrongfully convicted and spending years behind bars. However, the defendant may succeed in reversing the conviction on appeal or in habeas corpus. But then, the concern is the remedy for the defendant for all the harm he has suffered.
Furthermore, critics argue that the ruling exempting officers from civil liability if they violate the Miranda rights may reduce their motivation to comply. Thus, jeopardizing the entire purpose of the Miranda Right. Furthermore, failing to sue law enforcement for intentionally violating Miranda rights will lead to officers acting with impunity for their unlawful actions.
Conclusion
Following the court ruling, the only remedy for violating the Miranda Right is to suppress (exclude) statements obtained from the suspect during a trial. But, there is no remedy for the unlawful actions of the officers if the case never goes to trial. There is also no remedy if the government never seeks to use the statement or if the evidence gets admitted despite the Miranda right violation.
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