“My Mirandas Don’t Stand a Chance, with Cops”: The U.S. Supreme Court’s Impending Destruction of Miranda Rights Under the Pretense of Prophylaxis in Vega v. Tekoh

In 2022, in Vega v. Tekoh, the U.S. Supreme Court held that individuals interrogated without knowledge of their Miranda rights cannot seek remedy under 42 U.S.C. § 1983. The Supreme Court’s rationale for this decision was that the right provided in the 1966 Miranda v. Arizona decision, which ensures that those facing the criminal legal system are provided information on their privileges, was not a constitutional right, and it would therefore be impermissible to seek remedy for a right that does not exist. Instead, the Court labeled Miranda rights as a prophylactic rule: a practice that exists to help protect constitutional rights but is itself not constitutionally required. With this decision, the Court is positioned to soon overturn Miranda. The job of the American judiciary is to create rulings that adhere to and uphold rights afforded under the U.S. Constitution. Prophylactic rules are no different. This Note argues that the decision in Vega v. Tekoh will hinder people—especially those from marginalized communities—from attaining the justice to which they are entitled. This disenfranchisement should be addressed through congressional action or initiatives taken by state legislatures to protect marginalized people from the injustices of the criminal legal system.