Vega v. Tekoh, 597 U.S. 134

Deputy Carlos Vega questioned Terence Tekoh at his workplace about an alleged sexual assault and did not give Miranda warnings; Tekoh signed a written apology/confession.
Tekoh was prosecuted in state court; the un‑Mirandized statement was admitted at trial and he was acquitted on retrial.
Tekoh sued Vega under 42 U.S.C. §1983 seeking damages for violation of his Fifth Amendment privilege against self‑incrimination based on the use of the un‑Mirandized statement.
The Ninth Circuit held that using an un‑Mirandized statement at trial violates the Fifth Amendment and supports a §1983 claim; the Supreme Court granted certiorari.
The Supreme Court reversed: it held that Miranda’s warnings are prophylactic (not equivalent to the Fifth Amendment itself) and that Miranda violations do not, by themselves, give rise to §1983 damages claims; it also declined to expand Miranda into a freestanding right to sue for damages under §1983.
Justice Kagan dissented, arguing Miranda is a constitutionally based rule (per Dickerson) that creates enforceable rights under §1983 and that denying a §1983 remedy improperly strips victims of redress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Miranda violation is a Fifth Amendment violation giving rise to §1983 liability	Tekoh: An un‑Mirandized statement used at trial violates the Fifth Amendment and thus constitutes a §1983 deprivation	Vega: Miranda is a prophylactic judicial rule to protect the Fifth Amendment; its breach is not necessarily a constitutional violation	No — Miranda violations are prophylactic and do not necessarily equal a Fifth Amendment violation for §1983 purposes
Whether Miranda (as judicially created law) confers a private right to sue for damages under §1983	Tekoh: Dickerson treats Miranda as a constitutional rule, so its protections are "rights secured by the Constitution" enforceable under §1983	Vega: Expanding §1983 would impose heavy costs (re‑litigation, federal‑state friction, procedural complexity) and add little deterrence beyond existing remedies	No — Court declined to extend §1983 to create a damages remedy for ordinary Miranda violations; suppression at trial is generally the adequate remedy

Miranda v. Arizona, 384 U.S. 436 (1966) (established custodial warnings; framed those warnings as prophylactic safeguards to protect the Fifth Amendment)
Dickerson v. United States, 530 U.S. 428 (2000) (held Miranda is a "constitutional rule" that cannot be abrogated by statute while treating Miranda as prophylactic in scope)
Michigan v. Tucker, 417 U.S. 433 (1974) (distinguished Miranda violations from direct constitutional infringements; fruits of Miranda violations are not automatically suppressed)
Harris v. New York, 401 U.S. 222 (1971) (held statements obtained in violation of Miranda may be used to impeach a defendant)
Oregon v. Elstad, 470 U.S. 298 (1985) (refused to extend fruit‑of‑the‑poisonous‑tree suppression to all Miranda errors; later valid waiver can admit subsequent statements)
Doyle v. Ohio, 426 U.S. 610 (1976) (held post‑warning silence cannot be used to impeach; an example of expanding Miranda’s prophylaxis)
Withrow v. Williams, 507 U.S. 680 (1993) (rejected limiting Miranda’s application in collateral proceedings by analogy to Stone v. Powell)
United States v. Patane, 542 U.S. 630 (2004) (held Miranda does not require suppression of physical evidence that is the fruit of an unwarned but voluntary statement)
Chavez v. Martinez, 538 U.S. 760 (2003) (plurality/concurring views limiting §1983 damages for certain unwarned custodial interrogations)