Written by attorneys · grounded in primary & secondary sources — see below
A deputy or substitute for another who acts with vicarious authority. The term forms part of titles for subordinate government and military officials whose duties may devolve from a higher official.
Sources & Authorities
How it applies
Common Examples
6
Legislators Challenge Tie-Breaking Vote
State senators Liam Larson and Logan Lane voted against a bill. The lieutenant governor cast the tie-breaking vote that enacted the measure. The senators sued, claiming the executive action nullified their votes and caused them concrete injury.
Supervisor Authority in Harassment Claim
Employee Lucia Lopez reported repeated harassment by her shift lieutenant at the university pool. The lieutenant assigned work, recommended discipline, and influenced evaluations that affected pay. Lopez sued the university under Title VII, arguing the lieutenant qualified as a supervisor.
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Cases
Restatements
Dictionaries
Vance v. Ball State University570 U.S. 421 (2013)
Promotion Quotas for Fire Lieutenant
Firefighter Luke Latham challenged consent decrees that set temporary promotion rates for fire lieutenant positions. The decrees required the city to promote qualified black and white candidates at equal rates until goals were met. Latham argued the quotas unlawfully limited his advancement opportunities.
Martin v. Wilkes490 U.S. 755, 762 n.2 (1989)
Police Lieutenant Questions Suspect
Detective Leonard Lowe arrested a murder suspect and left him with a local lieutenant. The lieutenant continued interrogation after the suspect's attorney had contacted the station. The suspect later moved to suppress his statements, claiming the lieutenant violated his right to counsel.
Moran v. Burbine475 U.S. 412 (1986)
Military Exclusion Order Issued
Lieutenant General Lucas Lee issued a proclamation excluding persons of Japanese ancestry from designated coastal areas. A resident named Korematsu remained in the area and was convicted for violating the order. He challenged the conviction on constitutional grounds.
Korematsu v. United States323 U.S. 214 (1944)
Navy Crash Report Admitted
The estate of Lieutenant Commander Barbara Ann Rainey introduced a Navy investigative report after a training aircraft crash. The report contained opinions on the cause of the accident. The defendant manufacturer objected that the opinions exceeded the scope of admissible public records.
Beech Aircraft Corp. v. Rainey499 U.S. 153 (1988)
Common questions
Frequently Asked
6
When does a lieutenant governor's vote create standing for legislators?+
Legislators have standing when the lieutenant governor's tie-breaking vote nullifies their votes and enacts a specific outcome that injures them personally.
Supporting sources
Can a lieutenant qualify as a supervisor under Title VII?+
A lieutenant may qualify as a supervisor if the position includes authority to recommend tangible employment actions such as discipline or pay changes that affect subordinates.
Supporting sources
How does the term lieutenant appear in promotion decree litigation?+
Courts have reviewed decrees that set temporary promotion rates for fire lieutenant positions to remedy past discrimination while preserving qualifications standards.
Supporting sources
Does a police lieutenant's interrogation raise Sixth Amendment issues?+
Statements taken by a lieutenant after counsel has contacted authorities may be suppressed if the interrogation violates the suspect's right to have an attorney present.
Supporting sources
What role did a lieutenant general play in wartime exclusion orders?+
A lieutenant general designated as military commander issued proclamations excluding designated persons from military areas under executive authority.
Supporting sources
Are opinions in a lieutenant commander's crash report admissible?+
Opinions and conclusions in an official investigative report about an aircraft accident may be admitted as public records if they meet the requirements for trustworthiness.
Supporting sources
499 U.S. 153 (1988)Evidence
…crash of a Navy training aircraft at Middleton Field, Alabama, on July 13, 1982, which took the lives of both pilots on board, Lieutenant Commander Barbara Ann Rainey and Ensign Donald Bruce Knowlton. The accident took place while Rainey, a Navy flight instructor, and Knowlton, her student, were flying "touch-and-go"…