Citation
United States v. Salerno, 481 U.S. (1987)
Facts
The United States v. Salerno was a case brought to the Court of Appeal when Anthony Salerno, an American Mafia member was arrested and detained for violating the Racketeer Influenced and Corrupt Organizations Act. The 1984 Bail Reform Act allowed for the federal courts to detain an arrested person prior to trial if the government could demonstrate that the individual was potentially dangerous to the society. The prosecution argued that Salerno, of the La Costa Nostra crime family, presented such threat to the community.
Issue
Did the Bail Reform Act violate the Fifth Amendment’s Due Process Clause?
Holding
Given the Bail Reform Act’s authentic and compelling regulatory purpose and the procedural protections that it offers, it is not facially invalid under the Due Process Clause or Excessive Bill Clause. The Court recognized the well-established doctrine, which provides a different standard for facial challenges of laws alleged to violate the First Amendment.
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Rationale
The Supreme Court held that the Act was constitutional because when the government’s interest in protecting the community outweighs individual liberty, detention before the trial can be a potential solution to a pressing societal problem. This Act applies only to a specific group of the potential threat and does not prevent the accused from enjoying a speedy trial.
Rule
The Supreme Court dismissed Salerno’s argument that the Act violated the Excessive Bail Clause of the Eighth Amendment. It resolved that the Bail Reform Act of 1984 was constitutional, and had violated neither the US Constitution’s Due Process Clause of the Fifth Amendment nor its Excessive Bail Clause of the Eighth Amendment ( United States v. Salerno ).
Impact
The ruling made by the United States Supreme Court established the criterion for detaining a potentially dangerous person to the community, which is before the trial, also known as pre-trial detention. This case ruling also set the conditions, privileges, and rights of such a person under detention.
References
United States v. Salerno , 481 U.S. (1987)
