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Ensuring Due Process: Analysing United States v. Sanchez-Gomez in the U.S. Criminal Justice System

The Fifth Amendment of the United States Constitution protects the rights of individuals in legal matters specifically through its due process clause. This clause ensures that no person can be deprived of life, liberty, or property without the proper application of the law. Its primary objective is to safeguard citizens from unjust legal actions and underscore the imperative need for equitable legal proceedings, which guarantees that all individuals receive just treatment within the justice system. The due process clause encompasses two essential components: Substantive Due Process and Procedural Due Process. Substantive Due Process revolves around the notion that certain rights are protected by the Constitution and cannot be infringed upon by legislative actions. It serves as a barrier against the government enacting laws that violate an individual's freedom of speech, expression or religion. Procedural Due Process, on the other hand, ensures that individuals receive fair and efficient trials whenever their rights are at stake. This entails adhering to legal procedures and providing a fair trial before any infringement on their rights can occur. For instance, during courtroom proceedings, individuals are legally entitled to a fair hearing and an impartial decision maker who renders unbiased rulings.


The Fifth Amendment enforces the principle of “innocent until proven guilty”, although the history of the United States justice system reveals a persistent conflict between this ideal and the lived experiences. This conflict becomes particularly relevant when individuals believe they have been deprived of due process under the law. Such concerns were highlighted in the case of United States v. Sanchez-Gomez (2018), where the Fifth Amendment was at the centre of the defendant’s contention that he had not been granted due process.


Rene Sanchez-Gomez, along with three co-defendants, faced the practice of being shackled during pretrial proceedings in a California courtroom. He sought to have this practice abolished, arguing that it violated his fifth amendment rights to due process. The practice of shackling defendants in California courtrooms originated from a 2013 incident wherein a prisoner assaulted another individual within a judge’s courtroom. Subsequently, U.S. Marshal Steven Stafford requested permission from the Chief Justice to establish a policy that required defendants to appear fully restrained in court. The Chief Justice approved his request, leading to the implementation of this practice for all defendants.


Defendant Sanchez-Gomez filed a petition with the Ninth Circuit court, seeking a review of the constitutionality of the rule that allowed for the shackling of defendants before their guilt was established. He argued that this practice violated their due process rights and infringed upon their right to a fair trial. Initially, the case was dismissed, citing United States v. Howard (1957), a previous case that upheld the full restraint policy. However, a year later, the case was reconsidered when a motion was proposed to have the case reheard. The court deemed the policy unconstitutional. The court asserted that the policy violated the defendant's right to be free from unnecessary shackles, as no justifiable purpose for the restraints could be established.


In addressing this matter, the court delved into a broader issue pertaining to the recognition of fundamental rights within the courtroom. Consequently, the right to be free from unnecessary restraints and shackles became a federally acknowledged right and is now respected by all U.S. courts. Shackling is now permissible only when evidence of its necessity is presented. The court reaffirmed the principle that defendants are presumed innocent until proven guilty, emphasising their entitlement to be treated with dignity and respect throughout the legal process. This ruling has underscored the significance of conducting court proceedings in a manner that upholds proper and appropriate standards. However, dissenting judges argued that since the defendant’s criminal case was no longer active, the case should be considered moot, and the question of constitutionality should not have been addressed.


In 2018, the Supreme Court rendered the case moot, as the controversy and relevance surrounding it were no longer active. The defendants in Sanchez-Gomez were no longer undergoing trial, and the policy of full shackling in courtrooms had been revised and replaced with a new policy that considerably restricted the use of restraints. This new policy deemed restraints unnecessary unless a defendant has shown evidence that would result in restraints being needed to get through court proceedings. Although the decision in United States v. Sanchez-Gomez did not establish a fresh legal precedent concerning restraints in courtrooms, it established a new fundamental right and played an important role in shaping the Mootness Doctrine.


The Mootness Doctrine is grounded in the pertinence and circumstances of a case within legal proceedings. It empowers federal courts to adjudicate cases that involve pertinent issues necessitating resolution. A case becomes moot when it loses relevance, rendering a judicial decision unnecessary.


Ultimately, United States v. Sanchez-Gomez has brought about noteworthy transformations in the legal system. It has helped clarify the Mootness Doctrine and has sparked essential inquiries in the U.S. Criminal Justice system. This case not only resolved contentious practices in courtrooms and expanded the rights of pretrial defendants. but has also contributed to a broader discourse on criminal justice and prison reform. The application of Substantive Due Process, in this case, presents an opportunity to shed light on issues within the U.S. prison system and other injustices prevalent in the criminal justice system that contribute to problems such as mass incarceration, unfair treatment of defendants, and disregard for human rights. This case identifies the U.S. government's responsibility to refrain from infringing upon individuals’ constitutional and fundamental freedoms. It holds the potential to pave the way for future reforms aimed at improving living conditions in prisons, defending fundamental human rights, dignity for prisoners and reducing the overall number of incarcerated individuals nationwide.


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