Immigration and Naturalization Service v. St. Cyr
Encyclopedia
Immigration and Naturalization Service v. St. Cyr, 533 U.S. 289
(2001) is a United States
Supreme Court
case involving habeas corpus
relief for deportable aliens.
violation in Connecticut
. Under U.S. Immigration Law, St. Cyr, a lawful permanent resident for ten years and a citizen of Haiti
, became deportable by being convicted of the controlled substance violation. Before the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) § 212(c) of the Immigration and Nationality Act of 1952 was interpreted to give the Attorney General
broad discretion to waive deportation of resident aliens. The AEDPA and IIRIRA, however, limited the class of aliens who can apply for relief. Attorney General John Ashcroft
argued that the new federal laws stripped him of the authority to grant St. Cyr a waiver. St. Cyr, who had pleaded guilty before the new federal laws were enacted but had deportation proceedings brought against him after the new federal laws were enacted, conceded deportability but argued that he was entitled to a writ of habeas corpus. The District Court accepted St. Cyr's habeas corpus application and agreed that the new restrictions do not apply to removal proceedings brought against an alien who pleaded guilty to a deportable crime before their enactment.
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 § 212(c) relief to aliens who would have been eligible for such relief at the time of their convictions. 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.
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.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2001) is a United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case involving habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
relief for deportable aliens.
Facts
Enrico St. Cyr pleaded guilty to a controlled substanceControlled substance
A controlled substance is generally a drug or chemical whose manufacture, possession, or use are regulated by a government. This may include illegal drugs and prescription medications ....
violation in Connecticut
Connecticut
Connecticut is a state in the New England region of the northeastern United States. It is bordered by Rhode Island to the east, Massachusetts to the north, and the state of New York to the west and the south .Connecticut is named for the Connecticut River, the major U.S. river that approximately...
. Under U.S. Immigration Law, St. Cyr, a lawful permanent resident for ten years and a citizen of Haiti
Haiti
Haiti , officially the Republic of Haiti , is a Caribbean country. It occupies the western, smaller portion of the island of Hispaniola, in the Greater Antillean archipelago, which it shares with the Dominican Republic. Ayiti was the indigenous Taíno or Amerindian name for the island...
, became deportable by being convicted of the controlled substance violation. Before the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) § 212(c) of the Immigration and Nationality Act of 1952 was interpreted to give the Attorney General
United States Attorney General
The United States Attorney General is the head of the United States Department of Justice concerned with legal affairs and is the chief law enforcement officer of the United States government. The attorney general is considered to be the chief lawyer of the U.S. government...
broad discretion to waive deportation of resident aliens. The AEDPA and IIRIRA, however, limited the class of aliens who can apply for relief. Attorney General John Ashcroft
John Ashcroft
John David Ashcroft is a United States politician who served as the 79th United States Attorney General, from 2001 until 2005, appointed by President George W. Bush. Ashcroft previously served as the 50th Governor of Missouri and a U.S...
argued that the new federal laws stripped him of the authority to grant St. Cyr a waiver. St. Cyr, who had pleaded guilty before the new federal laws were enacted but had deportation proceedings brought against him after the new federal laws were enacted, conceded deportability but argued that he was entitled to a writ of habeas corpus. The District Court accepted St. Cyr's habeas corpus application and agreed that the new restrictions do not apply to removal proceedings brought against an alien who pleaded guilty to a deportable crime before their enactment.
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 ? The substantive question was whether the federal laws deny relief under § 212(c) of the INA to aliens who would have been eligible for such relief at the time of their convictions?Decision
In a 5-4 opinion, Justice John Paul StevensJohn Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
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 § 212(c) relief to aliens who would have been eligible for such relief at the time of their convictions. Stevens reasoned that the Supreme Court should interpret statutes as avoiding constitutional
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
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 ScaliaAntonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
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
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
to use "magic words" to overcome the presumption of habeas corpus relief.