Case Summaries – Supreme Court of the United States (June 23, 2022)

This post summarizes cases decided by the Supreme Court of the United States on June 23, 2022. The cases are principally criminal law adjacent, but as appropriate may be added to Smith’s Criminal Case Compendium, a free and searchable database of case summaries from 2008 to present. Shea Denning prepared the summary of Nance v. Ward, and I prepared the others. An officer’s violation of a suspect’s Miranda rights is not a deprivation of the suspect’s constitutional rights for which the officer may be held liable under 42 U.S.C. § 1983. Vega v. Tekoh, 597 U.S. __, __ S. Ct. __ (June 23, 2022). Tekoh worked as a nursing assistant at a California hospital. A female patient accused him of sexually assaulting her. Deputy Vega investigated the allegation. “Vega questioned Tekoh at length in the hospital, and Tekoh eventually provided a written statement apologizing for inappropriately touching the patient’s genitals.” Tekoh was charged with unlawful sexual penetration. He moved to suppress his statement because Vega did not read him Miranda warnings, but the trial court ruled that he was not in custody and so not entitled to the warnings. Tekoh was subsequently acquitted by a jury. Tekoh then sued Vega under 42 U.S.C. § 1983, which applies when a state official deprives a person of “any rights, privileges, or immunities secured by the Constitution and laws.” Tekoh alleged that Vega violated his Fifth Amendment right against self-incrimination, including by failing to administer Miranda warnings. The federal district court judge determined that [...]