Legal Lapses: Vega v. Tekoh

Swasti Singhai, Final Focus Editor


Art by Ella Jiang

In March 2014, Los Angeles County Sheriff’s Deputy Carlos Vega questioned Terence Tekoh, a certified nursing assistant at a Los Angeles Medical Center, after a sexual assault claim was brought forth against him. While it was disputed whether or not Vega used coercive investigatory techniques, the fact that Vega never informed Tekoh of his rights under Miranda v. Arizona is undisputed. 

The Supreme Court in Miranda v. Arizona (1966) held that police officers must inform suspects in a custodial interrogation of their right to remain silent and their right to an attorney, rights commonly referred to as Miranda rights. 

The case was tried twice in California state courts, and while Tekoh was charged, the court refused his request to exclude his confession from evidence in both trials. The case then moved up to the Ninth Circuit Court of Appeals, which reversed the state courts’ decision, holding that the use of a statement obtained by the police without informing the suspect of his Miranda rights warranted a Section 1983 claim against Vega. Section 1983 lawsuits were created to remedy the violation of a federally protected right, such as Miranda rights, allowing the victim to seek monetary compensation, for one. It was created to protect civil rights. 

On June 23, the Supreme Court ruled 6-3 to reverse the Ninth Circuit decision.

Historically, Miranda rights have been protected; a violation of them generally invokes the exclusionary rule, which states that evidence obtained in violation of the Constitution is excluded from trial. 

However in Vega v. Tekoh, the Supreme Court disregarded precedent set in Miranda, with the majority stating that a violation of Miranda does not constitute a violation of the fifth amendment, as while Miranda rights are a set of rules that are “constitutionally based, they are prophylactic rules nonetheless.” Supreme Court Justice Samuel Alito argues that Miranda is prophylactic, or overprotective, of Fifth Amendment rights in the sense that Miranda extends beyond the enumerated rights in the Fifth Amendment. 

But the fact remains: Miranda is a constitutional rule, thus making it legally enforceable, as the court in Dickerson v. United States held, ruling that Congress could not overturn Miranda v. Arizona

Yet as a majority, the court denied this right, a right fundamental in criminal proceedings. They’ve erased precedent that has been set by the Supreme Court in the past, time and time again. By doing so, the court has erased every American’s rights and denied potential remedies to misconducted trials.