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INS v. St. Cyr
No. 00-767 (U.S. Sup. Ct. June 25, 2001) ; Clearinghouse Number: 53885
Description
Aliens Subject to Deportation Based on Criminal Convictions May Seek Habeas Corpus Relief in Federal Courts
Abstract
The U.S. Supreme Court held that aliens subject to deportation
based on criminal convictions had a right to appeal their
deportation orders to the federal courts. Respondent, a lawful
permanent resident, pleaded guilty to a criminal charge that made
him deportable. Although respondent would have been eligible for
waiver of deportation under the immigration law in effect when he
was convicted, his removal proceedings commenced after the
effective dates of the Antiterroism and Effective Death Penalty Act
and the Illegal Immigration Reform and Immigrant Responsibility
Act, which purported to exclude aliens convicted of criminal
offenses from waiver of deportation. The district court, in
accepting respondent’s habeas corpus application, found that
the new restrictions the two Acts imposed did not apply to removal
proceedings against an alien who pleaded guilty to a deportable
crime before their enactment. The Second Circuit affirmed, and the
Immigration and Naturalization Service appealed. Affirming, the
Supreme Court held that federal courts had jurisdiction under 28
U.S.C. § 2241 to decide the legal issue that
respondent’s petition raised. Noting that the
Constitution’s suspension clause unquestionably required some
judicial intervention in deportation cases, the Court found that
construing the two Acts to preclude court review of a question of
law would give rise to constitutional questions. To conclude that
the writ of habeas corpus was no longer available in this context
would be a departure from historical immigration law practice.
Finding that neither Act expressed a clear and unambiguous
statement of congressional intent to bar petitions under 28 U.S.C.
§ 2241, the Court held that waiver of deportation remained
available for aliens whose convictions came about through plea
agreements and who, notwithstanding those convictions, would have
been eligible for such relief at the time of their plea under the
law then in effect.
