United States v. Lanier

Background

A state chancery court judge was tried for repeatedly sexually assaulting women in his chambers between 1989 and 1991. He was convicted under a federal law that punishes officials who willfully deprive people of constitutional rights, but the full Court of Appeals reversed, saying no prior Supreme Court decision applied to such facts.

Reasoning

The Supreme Court examined whether the appeals court was right to demand a prior Supreme Court decision with facts “fundamentally similar” before a criminal prosecution could stand. The Court said the Constitution requires fair warning that conduct is criminal, but that warning can come from settled law generally—not only from identical Supreme Court precedents. It equated the fair-warning test for criminal prosecution with the civil “clearly established” standard that tells officials when their conduct is unlawfully actionable. Because the Sixth Circuit required an unnecessarily high and particularized showing of prior decisions, the Court held that standard was wrong.

Real world impact

The Supreme Court vacated the appeals court’s decision and sent the case back for reconsideration under the correct standard. Lower courts must ask whether prior law made the unlawfulness of an official’s conduct apparent, not whether a prior Supreme Court decision had identical facts. The ruling does not decide guilt or other defenses, which the lower courts must still address.

Dissents or concurrances

The opinion notes that judges on the appeals court were divided: some would have preserved certain felony counts while others voted to dismiss, a split that shaped the en banc outcome and the need for review.