United States v. Sanchez-Gomez

In United States v. Sanchez-Gomez, criminal defendants challenged the Southern District of California’s policy of routinely placing all pretrial detainees in full restraints during non-jury proceedings. Represented by federal public defenders, they argued the blanket shackling policy violated the Fifth Amendment’s Due Process Clause. The Ninth Circuit agreed and directed the district court to adopt individualized shackling procedures. By the time the case reached the Supreme Court, however, all defendants’ underlying criminal cases had concluded. The Supreme Court held that the case was moot because the defendants no longer had a personal stake in the outcome, and the “inherently transitory” exception to mootness did not apply. The Court vacated the Ninth Circuit’s judgment and remanded with instructions to dismiss, leaving the constitutional question unanswered.

The Supreme Court held that the case was moot, vacated the judgment of the Court of Appeals, and remanded with instructions to dismiss.

Whether the case became moot after the conclusion of the defendants’ criminal proceedings, and whether the district court’s blanket policy of full restraints on pretrial detainees during non-jury proceedings violates the Due Process Clause of the Fifth Amendment.

The decision prevented a definitive constitutional ruling on routine pretrial shackling, but concurring opinions highlighted serious due process concerns. It illustrated the procedural difficulty of challenging fleeting courtroom practices. Subsequently, several lower courts and judicial bodies revisited their shackling policies, and the case continues to be cited in debates over the limits of mootness and the regulation of in-custody appearances.