Caetano v. Massachusetts

Last updated

Jaime Caetano v. Massachusetts
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Decided March 21, 2016
Full case nameJaime Caetano v. Massachusetts
Docket no. 14-10078
Citations577 U.S. 411 ( more )
136 S. Ct. 1027; 194 L. Ed. 2d 99; 2016 U.S. LEXIS 1862
Opinion announcement Opinion announcement
Case history
PriorOn Petition for Writ of Certiorari to the Supreme Judicial Court of Massachusetts
ProceduralMotion to dismiss denied, sub nom. Commonwealth v. Caetano, No. 1149-CR-2522 (Mass. Dist. Ct. April 29, 2013); defendant convicted, No. 1149-CR-2522, Mass. Dist. Ct.; aff'd, 26 N. E. 3d 688 (Mass. 2015)
Holding
The Supreme Judicial Court of Massachusetts' erred in upholding a law that prohibited the possession of stun guns
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan
Case opinions
Per curiam
ConcurrenceAlito (in judgment), joined by Thomas
Laws applied
U.S. Const. amend. II; Mass. Gen. Laws, ch. 140, §131J (2014)

Caetano v. Massachusetts, 577 U.S. 411 (2016), was a landmark case in which the Supreme Court of the United States unanimously vacated a Massachusetts conviction of a woman who carried a stun gun for self-defense. [1]

Contents

Background

Jaime Caetano was reported to have been hospitalized and "in fear for [her] life" after an altercation with her "abusive" boyfriend. [2] After obtaining several restraining orders that "proved futile", Caetano accepted a stun gun from a friend for self-defense. [3] One night, when her ex-boyfriend confronted her outside her work and threatened her, she displayed the stun gun and successfully avoided an altercation. [3] However, when police discovered that she was in possession of the stun gun, she was arrested, tried, and convicted under a Massachusetts law that outlawed the possession of stun guns. [4] The Massachusetts Supreme Judicial Court had said her stun gun was "not the type of weapon that is eligible for Second Amendment protection" because it was "not in common use at the time of [the Second Amendment's] enactment." [5] Caetano then appealed the Massachusetts court's ruling to the Supreme Court of the United States. [6]

Opinion of the Court

In a per curiam decision, the Supreme Court vacated the ruling of the Massachusetts Supreme Judicial Court. [7] Citing District of Columbia v. Heller [8] and McDonald v. City of Chicago , [9] the Court began its opinion by stating that "the Second Amendment extends, prima facie, to all instruments that constitute bearable arms, even those that were not in existence at the time of the founding" and that "the Second Amendment right is fully applicable to the States". [6] The term "bearable arms" was defined in District of Columbia v. Heller , 554 U.S. 570 (2008) and includes any ""[w]eapo[n] of offence" or "thing that a man wears for his defence, or takes into his hands," that is "carr[ied] . . . for the purpose of offensive or defensive action." 554 U. S., at 581, 584 (internal quotation marks omitted)." [10]

The Court then identified three reasons why the Massachusetts court's opinion contradicted prior rulings by the United States Supreme Court. [1] First, the Massachusetts court said that stun guns could be banned because they "were not in common use at the time of the Second Amendment's enactment", but the Supreme Court noted that this contradicted Heller's conclusion that Second Amendment protects "arms ... that were not in existence at the time of the founding". [11] Second, the Massachusetts court said that stun guns were "dangerous per se at common law and unusual" because they were "a thoroughly modern invention", but the Supreme Court held that this was also inconsistent with Heller. [12] Third, the Massachusetts court said that stun guns could be banned because they were not "readily adaptable to use in the military", but the Supreme Court held that Heller rejected the argument that "only those weapons useful in warfare" were protected by the Second Amendment. [13]

Justice Alito's concurring opinion

Justice Samuel Alito wrote an opinion concurring in the judgment, in which he was joined by Justice Clarence Thomas. [3] Justice Alito characterized the per curiam decision as "grudging" and wrote that "[t]he reasoning of the Massachusetts court poses a grave threat to the fundamental right of self-defense". [14] He provided an analysis of why he believed that the Massachusetts court's ruling contradicted Heller and other cases interpreting the Second Amendment. [15] After concluding that the Massachusetts stun gun ban violates the Second Amendment, Justice Alito wrote: "if the fundamental right of self-defense does not protect Caetano, then the safety of all Americans is left to the mercy of state authorities who may be more concerned about disarming people than about keeping them safe". [16]

Subsequent developments

On July 6, 2016, after the prosecution and defense reached an agreement, Caetano was found not guilty by a Massachusetts judge. [17]

In a subsequent case, Ramirez v. Commonwealth, the Massachusetts Supreme Judicial Court relied on Caetano to strike down the state's stun gun law. [18] [19] [20] [21]

Commentary and analysis

Lyle Denniston observed that the Court's opinion was the first direct interpretation of the meaning of the Second Amendment since the Court's 2008 ruling in Heller. [22] However, given the limited nature of the per curiam opinion, Denniston noted that "[t]he facts in this case do not necessarily stand as a definite constitutional declaration". [22]

See also

Related Research Articles

<span class="mw-page-title-main">2006 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eight per curiam opinions during its 2006 term, which began October 2, 2006 and concluded September 30, 2007.

<span class="mw-page-title-main">2007 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down six per curiam opinions during its 2007 term, which began October 1, 2007 and concluded September 30, 2008.

McDonald v. City of Chicago, 561 U.S. 742 (2010), was a landmark decision of the Supreme Court of the United States that found that the right of an individual to "keep and bear arms", as protected under the Second Amendment, is incorporated by the Fourteenth Amendment and is thereby enforceable against the states. The decision cleared up the uncertainty left in the wake of District of Columbia v. Heller (2008) as to the scope of gun rights in regard to the states.

<span class="mw-page-title-main">2013 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eight per curiam opinions during its 2013 term, which began October 7, 2013 and concluded October 5, 2014.

Riley v. California, 573 U.S. 373 (2014), is a landmark United States Supreme Court case in which the court ruled that the warrantless search and seizure of the digital contents of a cell phone during an arrest is unconstitutional under the Fourth Amendment.

Kerry v. Din, 576 U.S. 86 (2015), was a United States Supreme Court case in which the Court analyzed whether there is a constitutional right to live in the United States with one's spouse and whether procedural due process requires consular officials to give notice of reasons for denying a visa application. In Justice Anthony Kennedy's concurring opinion, the controlling opinion in this case, he wrote that notice requirements “[do] not apply when, as in this case, a visa application is denied due to terrorism or national security concerns.” Because the consular officials satisfied notice requirements, there was no need for the Court to address the constitutional question about the right to live with one's spouse.

<span class="mw-page-title-main">2015 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eighteen per curiam opinions during its 2015 term, which began October 5, 2015 and concluded October 2, 2016.

Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.

Reed v. Town of Gilbert, 576 U.S. 155 (2015), is a case in which the United States Supreme Court clarified when municipalities may impose content-based restrictions on signage. The case also clarified the level of constitutional scrutiny that should be applied to content-based restrictions on speech. In 2005, Gilbert, Arizona adopted a municipal sign ordinance that regulated the manner in which signs could be displayed in public areas. The ordinance imposed stricter limitations on signs advertising religious services than signs that displayed "political" or "ideological" messages. When the town's Sign Code compliance manager cited a local church for violating the ordinance, the church filed a lawsuit in which they argued the town's sign regulations violated its First Amendment right to the freedom of speech.

Mullenix v. Luna, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States held that a police officer who shot a suspect during a police pursuit was entitled to qualified immunity. In a per curiam opinion, the Court held that prior precedent did not establish "beyond debate" that the officer's actions were objectively unreasonable.

OBB Personenverkehr AG v. Sachs, 577 U.S. ___ (2015), is a decision by the Supreme Court of the United States, holding that the Foreign Sovereign Immunities Act barred a California resident from bringing suit against an Austrian railroad in federal district court. The case arose after a California resident suffered traumatic personal injuries while attempting to board a train in Innsbruck, Austria. She then filed a lawsuit against the railroad in the United States District Court for the Northern District of California in which she alleged the railroad was responsible for causing her injuries. Because the railroad was owned by the Austrian government, the railroad claimed that the lawsuit should be barred by the Foreign Sovereign Immunities Act, which provides immunity to foreign sovereigns in tort suits filed in the United States. In response, the plaintiff argued that her suit should be permitted under the Foreign Sovereign Immunity Act's commercial activity exception because she purchased her rail ticket in the United States.

V.L. v. E.L., 577 U.S. 464 (2016), is a case decided by the Supreme Court of the United States concerning the adoption rights of same-sex couples. In 2007, a Georgia Superior Court granted adoption rights to V.L., the partner of E.L., the woman who gave birth to their three children. However, after moving back to Alabama, the couple split up. E.L. tried to block V.L. from seeing the children, but V.L. filed a lawsuit seeking visitation and other parental rights. On September 18, 2015, the Supreme Court of Alabama ruled that the state did not have to recognize the adoption judgment, saying that the Georgia court misapplied its own state law. The court voided the recognition of the adoption judgment in Alabama. V.L. petitioned the United States Supreme Court to stay the ruling during her appeal and allow her to see her children. On December 14, 2015, the Supreme Court stayed the ruling pending their action on a petition for a writ of certiorari filed by V.L. On March 7, 2016, the Supreme Court of the United States reversed the decision of the Alabama Supreme Court by per curiam summary disposition.

Luis v. United States, 578 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the pre-trial restraint of assets needed to retain a defendant's counsel of choice when those assets have not been used in conjunction with criminal activity.

Menominee Tribe of Wis. v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified when litigants are entitled to equitable tolling of a statute of limitations. In a unanimous opinion written by Justice Samuel Alito, the Court held that the plaintiff in this case was not entitled to equitable tolling of the statute of limitations because they did not demonstrate that "extraordinary circumstances" prevented the timely filing of the lawsuit.

Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.

Army Corps of Engineers v. Hawkes Co., 578 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that a Clean Water Act jurisdictional determination issued by the United States Army Corps of Engineers is reviewable under the Administrative Procedure Act because jurisdictional determinations constitute "final agency action". For a federal agency decision or action to be reviewable in court under the Administrative Procedures Act, it must be a “final” agency action, meaning that there are no further steps that can be taken before it has an impact on the legal rights or obligations of any affected parties.

<span class="mw-page-title-main">2016 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down nine per curiam opinions during its 2016 term, which began October 3, 2016 and concluded October 1, 2017.

New York State Rifle & Pistol Association, Inc. v. City of New York, New York, 590 U.S. ___ (2020), abbreviated NYSRPA v. NYC and also known as NYSRPA I to distinguish it from the subsequent case, was a case addressing whether the gun ownership laws of New York City, which restrict the transport of a licensed firearm out of one's home, violated the Second Amendment to the United States Constitution, the U.S. Constitution's Commerce Clause, and the right to travel. It was the first major gun-related case that the Supreme Court had accepted for review in nearly ten years, after District of Columbia v. Heller (2008) and McDonald v. City of Chicago (2010). After the Supreme Court agreed to hear the case, New York City and New York state amended its laws to allay the challenged provision. In a per curiam decision in April 2020, the Supreme Court determined that the case was moot, vacating and remanding the case to lower courts to determine "whether petitioners may still add a claim for damages in this lawsuit with respect to New York City's old rule".

<span class="mw-page-title-main">2019 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down ten per curiam opinions during its 2019 term, which began October 7, 2019 and concluded October 4, 2020.

<span class="mw-page-title-main">2021 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eight per curiam opinions during its 2021 term, which began October 4, 2021 and concluded October 2, 2022.

References

  1. 1 2 Caetano v. Massachusetts,No. 14–10078 , 577 U.S. ___, slip op. at 1-2 (2016) (per curiam).
  2. ↑ Caetano, slip op. at 1 (Alito, J., concurring in the judgment) (internal quotations omitted) (modification in slip opinion).
  3. 1 2 3 Caetano, slip op. at 1 (Alito, J., concurring in the judgment).
  4. ↑ Caetano, slip op. at 2 (Alito, J., concurring in the judgment) (citing Mass. Gen. Laws, ch. 140, § 131J (2014).
  5. ↑ Caetano, slip op. at 1 (Alito, J., concurring in the judgment) (citing 470 Mass. 774, 781) (internal quotations omitted) (modification in slip opinion).
  6. 1 2 Caetano, slip op. at 1 (per curiam).
  7. ↑ Caetano, slip op. at 2 (per curiam).
  8. ↑ District of Columbia v. Heller , 554 U.S. 570 (2008).
  9. ↑ McDonald v. City of Chicago , 561 U.S. 742 (2010).
  10. ↑ Caetano v. Massachusetts, 577 U.S. 411 (2016), slip op. at 4, footnote 3 (Alito, J., concurring in the judgment).
  11. ↑ Caetano, slip op. at 1 (per curiam) (citing Heller, 554 U.S., at 582) (internal quotations omitted).
  12. ↑ Caetano, slip op. at 1-2 (per curiam) (citing 470 Mass., at 781) (internal quotations omitted).
  13. ↑ Caetano, slip op. at 1-2 (per curiam) (citing 470 Mass., at 781; Heller, 554 U.S., at 624–25) (internal quotations omitted).
  14. ↑ Caetano, slip op. at 9 (Alito, J., concurring in the judgment).
  15. ↑ Caetano, slip op. at 4-8 (Alito, J., concurring in the judgment).
  16. ↑ Caetano, slip op. at 10 (Alito, J., concurring in the judgment).
  17. ↑ Volokh, Eugene (July 7, 2016). "Charges dropped in Caetano v. Massachusetts Second Amendment stun gun case". The Washington Post.
  18. ↑ No. SJC-12340, 2018 Mass. LEXIS 237 (April 17, 2018)
  19. ↑ "Massachusetts court strikes down ban on stun guns". Boston.com. April 17, 2018. Retrieved April 24, 2018.
  20. ↑ "Massachusetts High Court Strikes Down Stun Gun Ban". Reason.com. April 17, 2018. Retrieved April 18, 2018.
  21. ↑ "Jorge Ramirez vs. Commonwealth" (PDF).
  22. 1 2 Denniston, Lyle (March 21, 2016). "The Second Amendment expands, but maybe not by much". SCOTUSblog.
This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.