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United States v. Lanier

520 U.S. 259 (1997)

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United States v. Lanier

United States Supreme Court

520 U.S. 259 (1997)

Facts

David Lanier (defendant) was a state-court judge who sexually assaulted five women in his judicial chambers. Lanier was charged with 11 counts of willfully violating the women’s constitutional rights under color of law, under 18 U.S.C. § 242. Lanier was convicted on seven counts and appealed. A panel of the court of appeals affirmed the conviction, but the full court vacated that decision and granted rehearing en banc. The full court then reversed Lanier’s conviction and gave instructions to dismiss the indictment, finding that there had been a lack of notice that § 242 was applicable to sexual-assault crimes. The court held that criminal liability under § 242 could only be applied if the constitutional right said to have been violated had first been identified in a Supreme Court decision that held the right applied in a fundamentally similar situation. The Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Souter, J.)

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