United States v. Stacey Field
2014 U.S. App. LEXIS 12123
| 6th Cir. | 2014Background
- In 2000 Field was connected to a bank robbery investigation; FBI agents entered her father's vestibule without a warrant, later entered the home with her consent, and recovered money. She was interviewed while handcuffed, not Mirandized after requesting counsel, and was never formally arrested on the scene.
- Field and co-defendant Johnson were indicted; the government later dismissed Johnson’s charges (Bruton issues) and moved to dismiss Field’s charges after the district court granted her motions to suppress evidence and post-request-for-counsel statements. The indictment was dismissed without prejudice in December 2000.
- Over a decade later Field discovered FBI computerized records describing her as “arrested or received,” which she alleged were harming employment prospects; the FBI would not remove the record absent a court order.
- In 2011 Field (pro se) moved the district court to expunge the FBI arrest record; the court appointed counsel, considered briefing, and denied the motion for lack of jurisdiction relying on United States v. Lucido.
- On appeal the Sixth Circuit assumed (for argument) that federal courts may have ancillary jurisdiction to expunge records tied to unconstitutional arrests or convictions but held the district court still lacked ancillary jurisdiction to expunge Field’s FBI arrest record.
- The Sixth Circuit reasoned the suppression ruling and dismissal already vindicated the court’s authority and effectuated relief; the court never adjudicated that Field was illegally arrested, and expunging an executive-branch record was not necessary to manage proceedings, vindicate authority, or effectuate prior decrees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court had ancillary jurisdiction to expunge Field’s FBI arrest record | Field: arrest record was the direct result of unconstitutional FBI conduct; expungement is necessary to remedy injury | Gov't: No ancillary jurisdiction under Lucido; expungement not necessary to effectuate or vindicate court rulings | Court: No ancillary jurisdiction here; suppression and dismissal already vindicated court authority and effectuated relief |
| Whether suppression/dismissal required or justified court-ordered expungement of executive FBI records | Field: prior rulings imply record should be cleared to remove ongoing harm | Gov't: Suppression/dismissal remedied violations; expungement of independent executive records not required | Court: Suppression fully effectuated relief; expungement of separate FBI record not necessary to vindicate prior decrees |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (establishes limits and purposes of ancillary jurisdiction)
- Local Loan Co. v. Hunt, 292 U.S. 234 (ancillary equitable jurisdiction principles)
- United States v. Lucido, 612 F.3d 871 (6th Cir. 2010) (limiting ancillary jurisdiction for expungement on equitable grounds)
- United States v. Carey, 602 F.3d 738 (6th Cir. 2010) (ancillary jurisdiction exists where constitutional claims support expungement)
- United States v. Rowlands, 451 F.3d 173 (3d Cir. 2006) (ancillary jurisdiction limited to challenges to validity of underlying proceeding)
- United States v. Sumner, 226 F.3d 1005 (9th Cir. 2000) (ancillary jurisdiction for unlawful arrests/convictions)
- United States v. Meyer, 439 F.3d 855 (8th Cir. 2006) (extraordinary cases may warrant expungement to correct illegal proceedings)
- United States v. Coloian, 480 F.3d 47 (1st Cir. 2007) (no ancillary jurisdiction for purely equitable expungement requests)