California Federal Court Shackling Appeal Ruled Moot

For four federal criminal defendants in the Southern District of California, the United States Supreme Court just took away a little major victory they had scored on behalf of all federal criminal defendants in that federal district.

In the United States v. Sanchez-Gomez case, a unanimous Supreme Court reversed the holding of the Ninth Circuit, sitting en banc, that the Federal District Court for the Southern District of California's policy to shackle criminal defendants' hands and feet was unconstitutional. And while the Ninth Circuit truly grappled with the merits of the facts and law, SCOTUS saw an opportunity to give the whole case the old moot boot, and the whole Court took it.

Unanimous Mooting

While the High Court's decision itself is rather brief, this is primarily due to the fact that the merits of the actual issues were not dealt with. The majority opinion explains that the appellate court's decision was issued in error, as the court should have found the matter moot since each of the criminal defendants' cases had been resolved, and there was no longer an actual or concrete dispute.

In short, because there was no more need for relief for the actual parties, SCOTUS found that the "functional class action" status that the Ninth Circuit had used to confer relief, did not apply.

Curiously, in briefing the matter to the High Court, the criminal defendants argued that the matter was not moot because two of the four defendants could reoffend and be forced back into the court and shackled. However, like voluntary cessation not being strong enough to moot a request for injunctive relief, the possibility that one of the defendants could break the law again wasn't enough to stop the Court from finding mootness.

Related Resources:

• Lawyer Can't Concede Guilt When Client Claims Innocence (FindLaw's U.S. Supreme Court Blog)
• 9th Circuit: Courts Cannot Shackle All Defendants (FindLaw's U.S. Ninth Circuit Blog)