Immigration and Naturalization Service v. St. Cyr

Immigration and Naturalization Service v. St. Cyr, 533 U.S. 289 (2001), is a United States Supreme Court case involving habeas corpus and INA § 212(c) relief (repealed 1997) for deportable aliens.

INS v. St. Cyr
Argued April 24, 2001
Decided June 25, 2001
Full case nameImmigration and Naturalization Service v. Enrico St. Cyr
Citations533 U.S. 289 (more)
121 S. Ct. 2271; 150 L. Ed. 2d 347, 2001 U.S. LEXIS 4670
Case history
PriorDunbar v. INS, 64 F. Supp. 2d 47 (D. Conn. 1999); aff'd sub nom., St. Cyr v INS, 229 F.3d 406 (2d Cir. 2000); cert. granted, 531 U.S. 1107 (2001).
Holding
  1. AEDPA and IIRIRA did not divest district courts of their jurisdiction under the general habeas corpus statute.
  2. Aliens who pleaded guilty to criminal charges that rendered them deportable prior to the effective date of AEDPA and IIRIRA remain eligible for discretionary relief from deportation.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityStevens, joined by Kennedy, Souter, Ginsburg, Breyer
DissentO'Connor
DissentScalia, joined by Rehnquist, Thomas; O'Connor (parts I and III)
Laws applied
28 U.S.C. §§ 2241–2255

Facts

Enrico St. Cyr, a lawful permanent resident (LPR) of the United States for ten years and a citizen of Haiti, pleaded guilty to a controlled substance violation in Connecticut. Under the Immigration and Nationality Act (INA), St. Cyr became "removable" for having been convicted of a controlled substance violation.[1] Before the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA)[2] and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA),[3] INA § 212(c) was interpreted to give the U.S. Attorney General broad discretion to waive deportation of certain LPRs. The AEDPA and IIRIRA, however, limited relief to LPRs and non-LPRs. U.S. Attorney General John Ashcroft argued that AEDPA and IIRIRA stripped him of the authority to grant St. Cyr any waiver. St. Cyr, who had pleaded guilty on March 8, 1996, which was prior to the enactment of AEDPA and IIRIRA, had removal proceedings brought against him on April 10, 1997, after the enactment of these Acts, conceded removability but argued that he was entitled to a writ of habeas corpus. The U.S. District for the District of Connecticut accepted St. Cyr's habeas corpus application and agreed that the new restrictions do not apply to removal proceedings brought against an LPR who pleaded guilty to a deportable crime before the enactment of AEDPA and IIRIRA.[4] The U.S. Court of Appeals for the Second Circuit affirmed.[5]

Issues

The Supreme Court answered two questions. The first one was procedural. Do the AEDPA and IIRIRA strip federal district courts of habeas corpus jurisdiction over deportable aliens as previously granted under 28 U.S.C. § 2241? The substantive question was whether the federal laws deny relief under INA § 212(c) to LPRs who would have been eligible for such relief at the time of their convictions?

Decision

In a 5-4 opinion, Justice John Paul Stevens wrote for the majority stating that Congress did not intend to strip the federal district courts of their authority to hear habeas petitions from deportable aliens, and that the AEDPA and IIRIRA did not deny relief under INA § 212(c) to LPRs who would have been eligible for such relief at the time of their convictions.[6] Stevens reasoned that the Supreme Court should interpret statutes as avoiding constitutional issues, such as abridging the right to habeas corpus. He also argued that there is a presumption that administrative proceedings can be appealed to Article III federal courts.

Dissent

Justice Antonin Scalia dissented, arguing that the plain language of the AEDPA and IIRIRA stripped the federal district courts of jurisdiction to entertain habeas corpus petitions. He also argued that the majority was forcing Congress to use "magic words" to overcome the presumption of habeas corpus relief.

See also

References
  1. 8 U.S.C. § 1229a(e)(2) ("The term 'removable' means—(A) in the case of an alien not admitted to the United States, that the alien is inadmissible under section 1182 of this title, or (B) in the case of an alien admitted to the United States, that the alien is deportable under section 1227 of this title."); see also Tima v. Attorney General of the U.S., 903 F.3d 272, 277 (3d Cir. 2018); Galindo v. Sessions, 897 F.3d 894, 897 (7th Cir. 2018).
  2. Antiterrorism and Effective Death Penalty Act of 1996, Pub.L. 104–132 (text) (pdf), 110 Stat. 1214.
  3. Illegal Immigration Reform and Immigrant Responsibility Act of 1996, Pub.L. 104–208 (text) (pdf), 110 Stat. 3009-546, Div. C.
  4. Dunbar v. INS, 64 F. Supp. 2d 47 (D. Conn. 1999).
  5. St. Cyr v. INS, 229 F.3d 406 (2d Cir. 2000).
  6. Immigration and Naturalization Service v. St. Cyr, 533 U.S. 289 (2001).
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