Caetano v. Massachusetts

Caetano v. Massachusetts, 577 U.S. ___ (2016), was a 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]

Jaime Caetano v. Massachusetts
Decided March 21, 2016
Full case nameJaime Caetano v. Massachusetts
Docket no.14-10078
Citations577 U.S. ___ (more)
136 S. Ct. 1027; 194 L. Ed. 2d 99; 2016 U.S. LEXIS 1862
Opinion announcementOpinion 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, joined by Thomas
Laws applied
U.S. Const. amend. II; Mass. Gen. Laws, ch. 140, §131J (2014)

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]

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See also

References
  1. 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. 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. 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. ___ (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. Eugene Volokh, Charges dropped in Caetano v. Massachusetts Second Amendment stun gun case, Washington Post (July 7, 2016).
  18. No. SJC-12340, 2018 Mass. LEXIS 237 (Apr. 17, 2018)
  19. "Massachusetts court strikes down ban on stun guns | Boston.com". Boston.com. 2018-04-17. Retrieved 2018-04-24.
  20. "Massachusetts High Court Strikes Down Stun Gun Ban". Reason.com. 2018-04-17. Retrieved 2018-04-18.
  21. "JORGE RAMIREZ vs. COMMONWEALTH" (PDF).
  22. Lyle Denniston, The Second Amendment expands, but maybe not by much, SCOTUSblog (March 21, 2016).
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