OPINION ANALYSIS

Tantamount to nothing: Miranda “rights” can(not) be wronged

On Thursday, the Supreme Court released its opinion in Vega v. Tekoh, in which a 6-3 court held that a violation of Miranda v. Arizona does not provide a basis for civil damages under 42 U.S.C. § 1983. The majority’s decision both hobbles Miranda’s enforceability and unceremoniously strips the Constitution’s Fifth Amendment right against compelled self-incrimination of Miranda’s prophylactic protection, heretofore regarded as criminal procedure canon in American law. Specifically, the Vega majority held that governmental violation of Miranda – an undisputed “constitutional decision” that adopted a “constitutional rule” that is “constitutionally based” and has “constitutional underpinnings” – is not a violation of the Constitution. In other words: The government can violate Miranda without the threat of civil penalty, as the only remedy to right the government’s wrong is an evidentiary fix at trial: suppression of any confession obtained in violation of Miranda. Accordingly, Miranda is only an evidentiary trial rule, not a substantive constitutional right.

OPINION ANALYSIS

Divided court sides with government, cutting Medicare payments to safety-net hospitals

On Friday, in Becerra v. Empire Health Foundation, the Supreme Court had yet another chance to topple the Chevron doctrine, a stalwart of administrative law under which courts generally defer to federal agencies’ interpretations of ambiguous statutes. Apparently, though, a single earth-shattering decision was enough for one day. In a largely unremarkable 5-4 decision, the court upheld a 2005 regulation that reduces Medicare payments to “disproportionate share hospitals,” or “DSH hospitals.” The court made no mention of the Chevron doctrine, appearing to leave it intact.

The dispute in Empire Health centered on the meaning of the phrase “entitled to [Medicare Part A] benefits” in the Medicare payment statute for DSH hospitals. DSH hospitals serve a high percentage of low-income patients who are often in worse health and more costly to treat. The Medicare Act, which provides health insurance coverage for the nation’s elderly and disabled, pays DSH hospitals an enhanced rate to cover those higher costs.

WHAT WE'RE READING

The morning read for Monday, June 27

Each weekday, we select a short list of news articles, commentary, and other noteworthy links related to the Supreme Court. To suggest a piece for us to consider, email us at roundup@scotusblog.com.

Here’s the Monday morning read:

• Roe v. Wade Defined An Era. The Supreme Court Just Started A New One. (Amelia Thomson-DeVeaux, FiveThirtyEight)
• How to move forward after the destruction of Roe vs. Wade (Mary Ziegler, Los Angeles Times)
• Chief Justice John Roberts lost the Supreme Court and the defining case of his generation (Joan Biskupic, CNN)
• June 24, 2022: The Day Chief Justice Roberts Lost His Court (Adam Liptak, The New York Times)
• Abortion Ruling Highlights Diverging Paths of Justices John Roberts, Samuel Alito (Jan Wolfe, The Wall Street Journal)

Live

Announcement of orders and opinions for Monday, June 27 (complete)

We live blogged as the court released opinions in Ruan v. United States, Concepcion v. United States, and Kennedy v. Bremerton School District. 

Click here for a list of FAQs about opinion announcements.

Petitions of the Week

Another gun case waits in the wings

The Petitions of the Week column highlights a selection of cert petitions recently filed in the Supreme Court. A list of all petitions we’re watching is available here.

On Thursday, the court issued its first major ruling on the Second Amendment in over a decade, striking down a New York gun regulation and holding that the right to bear arms extends outside the home. Fourteen years earlier, the court’s modern jurisprudence on guns began with the decision in District of Columbia v. Heller, striking down a D.C. gun regulation and holding that the Constitution protects an individual right to keep guns inside the home. This week, we highlight cert petitions that ask the court to consider, among other things, whether a post-Heller regulation that prevents anyone in the District of Columbia with a “propensity for violence or instability” from obtaining a license to carry a gun is unconstitutionally vague.