Complaints Of Use Of Full Restraints Moot After Criminal Cases Ended

A group of criminal defendants challenged the policy of the United States District Court for the Southern District of California, which permitted officers to put in-custody defendants in full restraints for nonjury proceedings in court. The district court denied the claims, but while the appeal before the Ninth Circuit was pending all of the cases involving those defendants resolved. The Ninth Circuit held that the claims were a functional class action, and used the Supreme Court’s civil class action decisions to hold that the claims were not moot as a result of the underlying cases being resolved. The Court, in a unanimous decision by Chief Justice Roberts, reversed, holding that the claims could not be analogized to civil class actions claims, and thus were moot as soon as the underlying cases ended. The Court also held that the claims did not fall under the exception for cases that are capable of repetition, yet evading review, because the doctrine did not extend to those who would engage in further criminal conduct. A link to the decision in United States v. Sanchez-Gomez is here.