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United States v. Sanchez-Gomez

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Supreme Court of the United States
United States v. Sanchez-Gomez
Term: 2017
Important Dates
Argument: March 26, 2018
Decided: May 14, 2018
Outcome
Ninth Circuit vacated
Vote
9 -0 to vacate
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch


United States v. Sanchez-Gomez is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on March 26, 2018. The case came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit.

HIGHLIGHTS
  • The case: Four defendants who faced charges in federal district court challenged the policy of shackling all pretrial detainees when they appeared for pretrial hearings, regardless of the defendant's physical condition or assessed risk. The district court dismissed their challenges. The government argued that the court did not have the authority to rule on the defendants' claims; by the time of the appeal, all four defendants' cases had concluded, so they were no longer subject to the shackling policy. The United States Court of Appeals for the Ninth Circuit disagreed, concluding that it did have authority to consider the defendants' claims.
  • The issue: "Whether the court of appeals erred in asserting authority to review respondents' interlocutory challenge to pretrial physical restraints and in ruling on that challenge notwithstanding its recognition that respondents' individual claims were moot."[1]
  • The outcome: In a unanimous decision, the Supreme Court vacated the Ninth Circuit's judgment, holding that the court lacked the authority to rule on the defendants' claims because the case was moot.[2]


    • You can review the lower court's opinion here.[3]

    Background

    Legal question

    This was a case about a court's authority to hear a case. A court can only hear live controversies—that is, a court can only consider cases where the parties' dispute is ongoing. Generally, a court does not have authority to consider a case if the case is moot. A case is moot if the dispute between the parties has been resolved and the court's ruling would not change anything.

    There are several exceptions that allow a court to consider cases that are moot. One exception is for cases that are "capable of repetition, yet evading review."[3] That exception applies to situations where the circumstances that created the controversy do not last long enough for a court's decision to have any effect. The exception applies when “there is a reasonable expectation that the same complaining party will be subject to the same action again." For example, challenges to abortion laws by women seeking abortions fall within this category. Because pregnancy only lasts nine months, it is nearly impossible that a plaintiff seeking an abortion could gain judicial review of a law during her pregnancy—the challenge will evade review because the pregnancy will conclude before the review process concludes. But a plaintiff could become pregnant again and wish to file the same challenge—the challenge is capable of repetition. Thus, although the cases are likely to be technically moot by the time they are finally resolved—that is, the plaintiff is likely not pregnant anymore and so her case is not a live controversy—courts have authority to decide them under an exception to mootness. The exception applies to other situations where the controversy concludes before a court can rule but could arise again in the future for that same plaintiff.[3]

    Case background

    The United States Marshals Service asked the United States District Court for the Southern District of California for permission to fully shackle all defendants in all pretrial conferences. All but one of the judges on the court agreed to the policy. Although defendants were permitted to ask for an exception to the shackling rule, the judges did not generally grant exceptions. Four defendants who were subjected to pretrial shackling challenged the practice, arguing that it violated their constitutional rights.[3] When the district court dismissed their claims, they appealed to the United States Court of Appeals for the Ninth Circuit. By the time the case reached the Ninth Circuit, none of the four defendants was still in pretrial detention, meaning that none of them was still subject to the shackling policy. The Ninth Circuit heard the case twice. First, a three-judge panel heard the case; then, the Ninth Circuit heard the case en banc, meaning that the case was heard by the entire court. Before the Ninth Circuit heard the case en banc, the Southern District of California discontinued the shackling policy. The Ninth Circuit's en banc ruling was the ruling at issue in the case.[3]

    En banc opinion

    On appeal, a majority of the United States Court of Appeals for the Ninth Circuit ruled that 1) the court had authority to decide the case; and 2) the shackling policy violated defendants' rights.[3]

    The majority opinion was authored by then-Judge Alex Kozinski. The court first addressed whether the court had authority to hear the case. It acknowledged that because the defendants were no longer in pretrial detention, the shackling policy no longer affected them, so the application of the policy to the defendants in this case was moot. Moreover, the court continued, being a defendant in pretrial detention was not the kind of circumstance that falls within the mootness exception for cases that are "capable of repetition, yet evading review."[3]

    However, the court ruled that a live controversy still existed. The court noted that the defendants had not only objected to the shackling policy as applied to them but also sought to prevent the policy from being applied to any defendants. The court concluded that they had functionally filed a class action on behalf of other defendants, even though they had not followed the procedures to file a class action lawsuit nor expressly stated that they intended to file a class action suit. If the case was a class action, there were other defendants to whom the shackling policy could still be applied. The court further noted that although the district court had decided to discontinue the shackling policy, "the district court’s decision to change the policy was only a voluntary cessation. The appealed policy could be reinstated at any time. In fact, the government has indicated that it will seek to reinstate the policy unless we hold it unconstitutional." Therefore, the court concluded, there was still a live controversy in the case as to the rights of other defendants, and the case was not moot. Citing an earlier Supreme Court case, the court ruled:

    “ The Supreme Court itself has indicated that Gerstein's broadening of the capable-of-repetition-yet-evading-review mootness exception could apply to cases sufficiently similar to class actions...We are faced with an ever-refilling but short-lived class of in-custody defendants who are subject to the challenged pretrial shackling policy. At least some members of this functional class continue to suffer the complained-of injury. Most of the defendants are represented by the Federal Defenders of San Diego. And even if we must withhold a formal writ, we can provide district-wide relief by exercising our supervisory mandamus authority, thus demonstrating that there is a live controversy here. See Knox v. Serv. Emps. Int’l Union, Local 1000, 132 S. Ct. 2277, 2287 (2012) ("A case becomes moot only when it is impossible for a court to grant any effectual relief whatever to the prevailing party.")[3][4][5] ”

    Judge Mary Schroeder concurred in the court's judgment but wrote separately.[3]

    Judge Sandra Ikuta dissented, joined by four others. The dissent argued:

    “ Because the defendants have no ongoing interest in the purely prospective relief they seek, their appeals are moot unless some exception to the ordinary rules of mootness applies. But neither the Supreme Court nor our precedent has established any applicable exception. The majority implicitly concedes as much by contriving a new exception—the 'functional class action'—in order to rescue these appeals from mootness. Because this theory is inconsistent with Supreme Court precedent and incompatible with Article III’s case-or-controversy requirement, the majority’s creative effort to sidestep mootness should be rejected.[3][6][5] ”

    Petitioner's challenge

    The petitioner, the government, challenged the holding of the United States Court of Appeals for the Ninth Circuit. The government argued that the Ninth Circuit did not have authority to rule in this case.[3]

    Certiorari granted

    On August 29, 2017, the petitioner initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. The U.S. Supreme Court granted the petitioner's request for certiorari on December 8, 2017. Argument in the case was held on March 26, 2018.[1]

    Question presented

    Question presented:

    "Whether the court of appeals erred in asserting authority to review respondents' interlocutory challenge to pretrial physical restraints and in ruling on that challenge notwithstanding its recognition that respondents' individual claims were moot."[1]

    Audio

    • Audio of oral argument:[7]



    Transcript

    • Transcript of oral argument:[8]

    Outcome

    Decision

    In a unanimous ruling, the court held that the lower court lacked jurisdiction to rule on the defendants' claims because the case was moot.[2]

    Opinion of the court

    Chief Justice John Roberts authored the opinion for the unanimous court. Roberts wrote that the exception to mootness for cases that were "capable of repetition, yet evading review" did not apply in this case, because the defendants would only find themselves in the same position again if they were arrested for committing further criminal acts. Citing earlier cases, Roberts continued that the possibility of future criminal acts did not fall within the category of potentially repeated cases that the mootness exception was designed to prevent:

    “ Sanchez-Gomez and Patricio-Guzman are no longer in pretrial custody. Their criminal cases, arising from their illegal entry into the United States, ended in guilty pleas well before the Court of Appeals issued its decision. Respondents contend, however, that the claims brought by Sanchez-Gomez and Patricio-Guzman fall within the exception to the mootness doctrine for a controversy that is capable of repetition, yet evading review. A dispute qualifies for that exception only if (1) the challenged action is in its duration too short to be fully litigated prior to its cessation or expiration, and (2) there is a reasonable expectation that the same complaining party will be subjected to the same action again . . . Respondents argue that Sanchez-Gomez and Patricio-Guzman meet the second prong because they will again violate the law, be apprehended, and be returned to pretrial custody. But we have consistently refused to conclude that the case-or controversy requirement is satisfied by the possibility that a party will be prosecuted for violating valid criminal laws. We have instead assume[d] that [litigants] will conduct their activities within the law and so avoid prosecution and conviction as well as exposure to the challenged course of conduct.[2][9][5] ”


    The court vacated the Ninth Circuit's decision and instructed the lower court to dismiss the case as moot.[2]

    Text of the opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, "United States v. Sanchez-Gomez, Question Presented," December 8, 2017
    2. ↑ 2.0 2.1 2.2 2.3 United States Supreme Court, "United States v. Sanchez-Gomez Opinion," May 14, 2018
    3. ↑ 3.00 3.01 3.02 3.03 3.04 3.05 3.06 3.07 3.08 3.09 3.10 United States Court of Appeals for the Ninth Circuit, "United States v. Sanchez-Gomez, Opinion," May 31, 2017
    4. ↑ The court also addressed the merits of the defendants' claims. The court ruled that the shackling policy violated the defendants' constitutional rights. Citing Supreme Court precedent prohibiting defendants from being shackled during jury trials and sentencing, the court concluded, 'This right to be free from unwarranted shackles no matter the proceeding respects our foundational principle that defendants are innocent until proven guilty.' However, the merits of the defendants' claims were not at issue in the U.S. Supreme Court. The Supreme Court only considered whether the Ninth Circuit should have ruled that it had authority to decide the case.
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Internal citations omitted.
    7. ↑ Supreme Court of the United States, National Institute of Family and Life Advocates v. Becerra, argued March 26, 2018
    8. ↑ Supreme Court of the United States, United States v. Sanchez-Gomez, argued March 26, 2018
    9. ↑ Internal citations and quotations omitted.
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