WASHINGTON – The Supreme Court ruled Thursday that police officers cannot be tried under federal civil rights law for failing to apply the familiar warning required by a 1966 court ruling in the Miranda v. Arizona case. The vote was 6 to 3, with judges divided ideologically.
In a second case, the court ruled that a person sentenced to death in Georgia could invoke the same civil rights law when he wanted to be executed by shooting rather than by lethal injection. The vote was 5 to 4, with Chief Justice John G. Roberts Jr. and Judge Brett M. Cavanaugh joining the three Liberal members of the tribunal to form a majority.
The case of Miranda’s warnings illustrates the disputed status of the decision. Writing for the majority, Judge Samuel A. Alito Jr. said the decision declared something less than a constitutional right.
The case, Vega v. Tekoh, No. 21-499, was filed by Terence B. Teco, a hospital employee who was charged with sexually abusing a motionless patient receiving an emergency MRI scan. Mr. Teco was questioned in detail by Carlos Vega, deputy sheriff of Los Angeles.
The two men offered different accounts of the nature of the interrogation, but it was not disputed that Mr Vega had not warned Miranda that Mr Teko had signed a confession acknowledging the attack, that a State judge had admitted his confessions in evidence or that the jury acquitted him.
Mr. Teko then filed a lawsuit against Mr. Vega under the Civil Rights Act, known as Section 1983, which allows citizens to prosecute government officials, including police officers, for violations of constitutional rights.
Judge Alito wrote that the remedy for the violation of Miranda’s decision was to exclude the statements of the defendants during their criminal proceedings. The decision, he wrote, did not establish the type of constitutional law that could be justified by a 1983 section lawsuit.
Judge Alito acknowledged that Miranda’s rights had constitutional roots. But he wrote that “Miranda’s violation does not necessarily constitute a violation of the Constitution.”
“Miranda is based on a pragmatic assessment of what is needed to stop the violation in the Fifth Amendment process against forced self-incrimination,” Judge Alito wrote. “This prophylactic goal serves through the suppression during the process of statements received in violation of Miranda.
He added: “Allowing the victim of Miranda’s offense to sue a police officer for damages under section 1983 would have little added deterrent value, and resolving such claims would cause many problems.
Chief Justice Roberts and Judges Cavanaugh, Clarence Thomas, Neil M. Gorsuch and Amy Connie Barrett agreed with the majority.
In disagreement, Judge Elena Kagan wrote that the Supreme Court had repeatedly and categorically stated that Miranda had established constitutional law. This means that she wrote that employees who violated it must be subject to legal proceedings under section 1983.
“Today,” she writes, “the court deprives people of the opportunity to seek redress for violations of the right recognized in Miranda. The majority noted that the accused could still seek “suppression of statements received during the trial” in violation of Miranda’s procedures.
“But sometimes,” Judge Kagan continued, “such a statement will not be suppressed. And sometimes, as a result, the accused will be wrongly convicted and will spend years in prison. He may be able, on appeal or habeas, to overturn the sentence. But then what remedy does he have for all the damage he has suffered?
Judges Stephen G. Breyer and Sonia Sotomayor joined Judge Kagan’s disagreement.
Judge Kagan wrote the majority’s opinion in a second decision in civil rights cases, on whether a death row inmate in Georgia could try officials there on how he should be executed.
The prisoner, Michael Nance, claims that his constitutional right to be spared a cruel and unusual punishment under the Eighth Amendment will be violated if he is killed by lethal injection because his veins have been compromised.
Supreme Court precedents require prisoners who object to the methods of execution to identify an alternative. Mr. Nance proposed a firing squad, a method approved in four states but not in Georgia. He said Georgian officials could adapt one of the protocols to those other countries.
The case in question, Nance v. Ward, No. 21-439, was whether Mr. Nance could file a lawsuit under the Civil Rights Act. Judge Kagan said yes.
“The prisoner does not challenge the death sentence itself; he takes the validity of this sentence for granted, ”she wrote. “And he provides the state with a real plan to carry out the death sentence. If the prisoner receives the relief he has requested, it is because he has convinced the court that the state can easily use his offer to execute him. “
Disagreeing, Judge Barrett wrote that Mr Nance was required to lodge a complaint with the Habeas Corps and could not use the civil rights law as he sought to thwart his execution in practice.
“The court is looking too far along the way,” she wrote, suggesting that the potential acceptance of the firing squad by Georgia was speculation. “In my opinion, the consequences of the relief that a prisoner seeks depend on the state law that currently exists.
Judges Thomas, Alito and Gorsuch joined Judge Barrett’s disagreement.
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