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Stone v. INS
115 S.Ct. 1537 (U.S. Apr. 19, 1995) ; Clearinghouse Number: 50747
Description
Timely Motion for Reconsideration of Decision Upholding Deportation Order Does Not Toll 90-Day Period for Review of Final Order
Abstract
The Supreme Court has held that a timely motion for reconsideration
of a decision by the Bureau of Immigration Appeals (BIA) does not
toll the 90-day period for review of final deportation orders under
section 106(a)(1) of the Immigration and Nationality Act (INA).
Petitioner, a Canadian citizen, had been ordered deported after his
release from prison. The BIA denied his appeal of the deportation
order in July 1991 and denied his motion for reconsideration in
February 1993. Petitioner sought judicial review. The Sixth Circuit
dismissed the petition for want of jurisdiction to the extent that
the petition sought review of the July 1991 order, the underlying
deportation decision. In addition, the court of appeals held that
petitioner’s filing of the reconsideration motion did not
toll the 90-day filing period for review of final deportation
orders. Petitioner appealed. The Supreme Court rejected
petitioner’s argument that a timely motion to reconsider
renders the underlying order nonfinal and that a petition seeking
review of both the order and the reconsideration denial is timely
if filed within 90 days of the reconsideration denial. The Court
found that, by its terms, section 106(a)(6) of the INA contemplates
two petitions for review and directs the courts to consolidate the
matters. However, the Court found nothing in the statute indicating
that the filing of a petition for reopening or reconsideration
dislodges the earlier proceeding reviewing the underlying order; in
fact, the Court found that the statute directs that the motion to
reopen or reconsider be consolidated with the review of the order,
not the other way around. The Court concluded that the statute is
best understood as reflecting an intent on the part of Congress
that deportation orders are to be reviewed in a timely fashion
after issuance, notwithstanding the subsequent filing of a motion
to reopen or reconsider. The Court noted that underlying
considerations of administrative and judicial efficiency, as well
as fairness to the alien, supported its conclusion that Congress
intended to depart from the conventional tolling rule in
deportation cases.
