United States v. Sanchez-Gomez,
584 U.S. ___ (2018)

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Justia Opinion Summary

The Southern District of California adopted a districtwide policy permitting the use of full restraints—handcuffs connected to a waist chain, with legs shackled—on most in-custody defendants produced in court for non-jury proceedings by the U.S. Marshals Service. Before the Ninth Circuit could issue a decision on a challenge to the policy, the underlying criminal cases ended. That court—viewing the case as a “functional class action” seeking “class-like relief,” held that the case was not moot and the policy was unconstitutional. A unanimous Supreme Court vacated, finding the case moot. The federal judiciary may adjudicate only “actual and concrete disputes, the resolutions of which have direct consequences on the parties involved.”. Such a dispute “must be extant at all stages of review, not merely at the time the complaint is filed.” Precedent does not support a freestanding exception to mootness outside the Rule 23 class action context. The Federal Rules of Criminal Procedure establish for criminal cases no vehicle comparable to the civil class action, and the Supreme Court has never permitted criminal defendants to band together to seek prospective relief in their individual cases on behalf of a class. The “exception to the mootness doctrine for a controversy that is capable of repetition, yet evading review” does not apply, based only the possibility that some of the parties again will be prosecuted for violating valid criminal laws.

  • Syllabus  | 
  • Opinion (John G. Roberts, Jr.)

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus

United States v. Sanchez-Gomez et al.

certiorari to the united states court of appeals for the ninth circuit

No. 17–312. Argued March 26, 2018—Decided May 14, 2018

The judges of the United States District Court for the Southern District of California adopted a districtwide policy permitting the use of full restraints—handcuffs connected to a waist chain, with legs shackled—on most in-custody defendants produced in court for nonjury proceedings by the United States Marshals Service. Respondents Jasmin Morales, Rene Sanchez-Gomez, Moises Patricio-Guzman, and Mark Ring challenged the use of such restraints in their respective cases and the restraint policy as a whole. The District Court denied their challenges, and respondents appealed to the Court of Appeals for the Ninth Circuit. Before that court could issue a decision, respondents’ underlying criminal cases ended. The court—viewing the case as a “functional class action” involving “class-like claims” seeking “class-like relief,” 859 F. 3d 649, 655, 657–658—held that this Court’s civil class action precedents saved the case from mootness. On the merits, the Court of Appeals held the policy unconstitutional.

Held: This case is moot. Pp. 3–12.

(a) The federal judiciary may adjudicate only “actual and concrete disputes, the resolutions of which have direct consequences on the parties involved.” Genesis HealthCare Corp. v. Symczyk, 569 U. S. 66, 71. Such a dispute “must be extant at all stages of review, not merely at the time the complaint is filed.” Preiser v. Newkirk, 422 U. S. 395, 401. A case that becomes moot at any point during the proceedings is thus outside the jurisdiction of the federal courts. See Already, LLC v. Nike, Inc., 568 U. S. 85, 91. Pp. 3–4.

(b) In concluding that this case was not moot, the Court of Appeals relied upon this Court’s class action precedents, most prominently Gerstein v. Pugh, 420 U. S. 103. That reliance was misplaced. Gerstein was a class action respecting pretrial detention brought under Federal Rule of Civil Procedure 23. The named class representatives’ individual claims had apparently become moot before class certification. This Court held that the case could nonetheless proceed, explaining that due to the inherently temporary nature of pretrial detention, no named representative might be in custody long enough for a class to be certified. Gerstein does not support a freestanding exception to mootness outside the class action context. It belongs to a line of cases that this Court has described as turning on the particular traits of Rule 23 class actions. See, e.g., Sosna v. Iowa, 419 U. S. 393; United States Parole Comm’n v. Geraghty, 445 U. S. 388; Genesis HealthCare, 569 U. S. 66. The Federal Rules of Criminal Procedure establish for criminal cases no vehicle comparable to the civil class action, and this Court has never permitted criminal defendants to band together to seek prospective relief in their individual cases on behalf of a class. Here, the mere presence of allegations that might, if resolved in respondents’ favor, benefit other similarly situated individuals cannot save their case from mootness. See id., at 73. That conclusion is unaffected by the Court of Appeals’ decision to recast respondents’ appeals as petitions for supervisory mandamus. Pp. 4–9.

(c) Respondents do not defend the reasoning of the Court of Appeals, and instead argue that the claims of two respondents—Sanchez-Gomez and Patricio-Guzman—fall within the “exception to the mootness doctrine for a controversy that is capable of repetition, yet evading review.” Kingdomware Technologies, Inc. v. United States, 579 U. S. ___, ___ (internal quotation marks omitted). Respondents claim that the exception applies because Sanchez-Gomez and Patricio-Guzman will again violate the law, be apprehended, and be returned to pretrial custody. But this Court has 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.” O’Shea v. Littleton, 414 U. S. 488, 497. Respondents argue that this usual refusal to assume future criminal conduct is unwarranted here given the particular circumstances of Sanchez-Gomez’s and Patricio-Guzman’s offenses. They cite two civil cases—Honig v. Doe, 484 U. S. 305, and Turner v. Rogers, 564 U. S. 431—in which this Court concluded that the expectation that a litigant would repeat the misconduct that gave rise to his claims rendered those claims capable of repetition. But Honig and Turner are inapposite because they concerned litigants unable, for reasons beyond their control, to prevent themselves from transgressing and avoid recurrence of the challenged conduct. Sanchez-Gomez and Patricio-Guzman, in contrast, are “able—and indeed required by law”—to refrain from further criminal conduct. Lane v. Williams, 455 U. S. 624, 633, n. 13. No departure from the settled rule is warranted. Pp. 9–12.

859 F. 3d 649, vacated and remanded.

Roberts, C. J., delivered the opinion for a unanimous Court.

Primary Holding

A challenge to court policies concerning restraints, brought by criminal defendants, was rendered moot by the resolution of their underlying criminal cases.

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