Supreme Court of the United States
Ryder v. United States
June 12, 1995515 U.S. 177
Summary
Chief Justice Rehnquist, writing for a unanimous Court, held that the de facto officer doctrine could not validate the actions of improperly appointed military appellate judges against Ryder's timely Appointments Clause challenge. A litigant who timely challenges the constitutional validity of an adjudicator's appointment is entitled to a merits determination and appropriate relief. Neither prospective-only application nor analogies to qualified immunity and the good-faith exception justified denying Ryder relief. Review by the properly constituted Court of Military Appeals did not supply the broader factual and sentencing review available before the Coast Guard Court of Military Review. The Court reversed and remanded for a hearing before a properly appointed panel, without deciding whether such appointment defects are susceptible to harmless-error review. There were no separate opinions.
Holding
- Application of the de facto officer doctrine to a timely Appointments Clause challenge.. A litigant who timely challenges the constitutional validity of an officer's appointment is entitled to a merits decision and appropriate relief; the de facto officer doctrine did not validate the challenged judges' actions here.
- Whether remedial discretion justified denying retrospective relief.. The Government's arguments based on prospective application, qualified immunity, and the Fourth Amendment good-faith exception did not justify withholding relief from Ryder.
- Whether subsequent review by the Court of Military Appeals supplied an adequate substitute for review by a properly appointed intermediate appellate panel.. Review by the Court of Military Appeals did not provide all the opportunities for relief available before a properly constituted Coast Guard Court of Military Review; Ryder was entitled to a hearing before a properly appointed panel.
Docket 94-431
Cited authorities
- 10 U.S.C. §816
- 10 U.S.C. § 866
- 10 U.S.C. § 866
- 10 U.S.C. §942
- 10 U.S.C. § 867
- Pub. L. 103-337, § 924
- 108 Stat. 2831
- 10 U.S.C. § 866
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