In May 2018, Chief Roberts of the United States Supreme Court wrote a unanimous opinion in the case of United States v. Sanchez-Gomez, which held that a challenge by several criminal defendants regarding a district’s policy of shackling pretrial detainees was moot. In these restraints, a person’s hands are handcuffed together and these handcuffs are then connected with a chain to another chain located around the person’s waist. The person’s feet are also shackled together.
How the Case Reached the Supreme Court
The United District Court for the Southern District of California had adopted a district-wide policy that allowed marshals to place all defendants in custody during pretrial in full restraints for nearly all nonjury proceedings. Four defendants who were subject to this procedure initiated the lawsuit based on the argument that the policy was not constitutional. The district court responded by denying these challenges. While the case was being appealed to the United States Court of Appeals for the 9th Circuit, however, the four defendants resolved their individual cases through either dismissal or guilty pleas. As a result, the Supreme Court was forced to determine whether resolution of these four cases left the case moot. Subsequently, the Supreme Court found that the case was moot.
The Nature of Interlocutory Appeals
It is important to understand that the cases involved in Sanchez-Gomez are interlocutory appeals, which are a distinct type of appeal. Interlocutory appeals are made while other elements of a case are still proceeding. To determine if an appeal can be made during a federal criminal trial, the Supreme Court articulated the “collateral order doctrine” which only permits appeals if three elements are satisfied. First, the outcome of the case must be conclusively determined by the issue. Two, the matter that is appealed must be collateral to the merits. Third, the matter must be effectively unreviewable if an immediate appeal is not permitted. The “collateral order doctrine” arose in the case of Cohen v. Beneficial Industrial Loan Coap in which the lower court required bonds to be posted in certain stockholder derivatives. The Sanchez case is considered an interlocutory appeal because while the case is still ongoing, the Ninth Circuit is considering whether it should adhere to its policy that requires all defendants in pretrial proceedings to wear physical restraints.
The Supreme Court’s Rationale
The Supreme Court rejected several arguments in reaching its opinion. This included the Supreme Court’s rejection of the argument that the controversy was not moot because it was capable of “repetition yet evading review.” The Supreme Court also declined to accept the 9th Circuit’s argument in favor of a freestanding exception to mootness. As a result, the Supreme Court held that the case does not escape mootness simply because the opinion could benefit other similarly situated individuals.
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