Without knowing the details, I'd suggest that perhaps a procedural violation is not the same as a deprivation of civil rights.
You have exactly the same rights, regardless of Miranda being stated.
I agree with that ruling. After all, we have all heard it on TV for decades, so I would bet each of us already has it memorized, even if we’ve never read it, ourselves.
“You have the right to remain silent…”
“But in another case, the Supremes hold that a Miranda violation does not give grounds for a Sec. 1983 lawsuit for deprivation of civil rights.”
This is a very narrow decision that relies on the fact the Miranda rules are not, in fact, laws but judicial rulings and are not absolute, as is The Fifth Amendment. I’m not sure about the line between de jure and de facto, but the Supreme Court decided that in this case.
“A §1983 claim may also be based on “the deprivation of any rights . . . secured by the . . . laws.”
But the argument that Miranda rules constitute federal “law” that can provide the ground for a §1983 claim cannot succeed unless Tekoh can persuade the Court that this “law” should be expanded to include the right to sue for damages under §1983.
“A judicially crafted” prophylactic rule should apply “only
where its benefits outweigh its costs,” Shatzer.”
Because it is a made up right. In the Miranda decision, the court called it a court created federal rule of criminal procedure. Over the years the court evolved the “rule” to be broader and broader, ultimately a “constitutional right” even though the right to be warned is not in the constitution and neither is the right to free attorneys. If proposed as a constructional amendment it would never have passed, even today.
Some big shot sports figure mouthing off brought me to notice this a few years back.