The Platform


Vega v. Tekoh, the U.S. Supreme Court case concerning Miranda warnings, was wrongly decided.

“The life of the law has not been logic: it has been experience.” – Oliver Wendell Holmes Jr.

If experience serves us right, episodes of abuse of power by law enforcement authorities are not unheard of. From the murder of George Floyd to the case of George Stinney, the world has witnessed and endured it all. At a juncture where the public anger and mistrust against the police are at its peak, one has yet to see a decline in cases of police brutality. Against this backdrop, I wish to examine the U.S. Supreme Court’s recent ruling in Vega v. Tekoh.

Almost everyone is familiar with “you have a right to remain silent, anything you say can be used against you in a court of law and you have a right to counsel (shortened).” In 1965, while deciding Miranda v. Arizona, the U.S. Supreme Court came up with the aforementioned set of guidelines to be read to any suspect while being taken into custody. In common parlance, they are now referred to as Miranda warnings. Miranda rights came up as a result of the Court’s interpretation of the Fifth Amendment. The Fifth Amendment guarantees a right against self-incrimination ensuring that nobody can be compelled to implicate themselves. Therefore, the Miranda warning became a constitutionally implicit rule and has been adhered to by law enforcement ever since.

In Vega v. Tekoh, an officer who took the accused into custody did not read him his Miranda rights and subsequently took a confession in the form of a letter. This letter was admitted as evidence in the trial, but the jury found the accused not guilty. However, the accused proceeded to sue the police officer under 42 US Code § 1983 claiming that the police officer’s conduct resulted in the violation of his rights. In a 6-3 decision, the U.S. Supreme Court ruled that Miranda rights are not a strict constitutional scheme and accordingly denied the claim.

The verdict importantly falters in its adherence to the principle of stare decisis. It is because the holding in the Miranda case was emphatically reaffirmed by the U.S. Supreme Court in the case of Dickerson v. United States. It is to be noted that as a matter of criminal procedure, any un-Mirandized confession is always excluded from a trial. The Dickerson case specifically elevates the stature of the Miranda warnings to a constitutional rule. As a result, it can be reasonably inferred that the Miranda standard is not a judicial rhetoric incapable of being enforced in a court of law. Justice Elena Kagan in her dissenting opinion effectively points out the power imbalance in these situations and the pressure of a “police dominated” environment in which an interrogation takes place.

As per the statute, in order to succeed in a § 1983 claim, it has to be established that there was a “deprivation of any rights, privileges, or immunities secured by the Constitution and laws.” Since the reading of Miranda to a suspect was deduced and interpreted from the Fifth Amendment of the U.S. Constitution; it can be classified as a constitutional ‘right’ in all fairness and legal propriety. The Court’s reluctance in upholding a sound civil rights claim sets an inauspicious judicial precedent.

Law enforcement authorities are conferred with tumultuous powers and it is usually the citizens who find themselves at the shorter end of the stick. The dilution of Miranda rights leaves Americans vulnerable. It is disheartening to witness the judiciary of a nation with a rich constitutional history encroach upon the rights of its citizens. By rolling back constitutional rights, the U.S. Supreme Court has demonstrated that it has lost its direction and is facing a crisis.

Anant Prakash Mishra is in his final year at WB National University of Juridical Sciences, Kolkata [Nujs]. Anant has a keen interest in constitutional and anti-discrimination laws.