United States v. Sanchez-Gomez

Respondents, four criminal defendants, challenged a full restraint policy that allowed law enforcement to use handcuffs connected to waist chains and leg shackles. The District Court denied the challenge. Respondents appealed, but before the Court of Appeals for the Ninth Circuit was able to grant a decision, the underlying criminal cases concluded.  Nevertheless, the Ninth Circuit decided that the issue was a “functional class action” that saved the case from mootness and held the restraint policy unconstitutional.  On Appeal, the Supreme Court found that the Ninth Circuit’s reliance on Gerstein v.Pugh, which allows for cases that are inherently transitory in nature to be saved from mootness, was improper.  The Supreme court reasoned that Gerstein was a civil case rather than a criminal case like the one at hand. The Court noted that it has never allowed criminal defendants to come together as a class in order to seek relief for their individual criminal cases. Respondents argued that this case represented a fictional class action because two of the respondents were capable of repetition of the controversy, protecting the case from mootness.  The Supreme Court found that this is not sufficient reasoning as the two respondents are able and required by law not to repeat their offenses. VACATED and REMANDED