Immigration and Naturalization Service v. St. Cyr
"Immigration and Naturalization Service v. St. Cyr" is a pivotal Supreme Court case that addressed the legality of federal judicial review in deportation proceedings, particularly in relation to habeas corpus petitions filed by deportable aliens. The case originated in 1996 when Enrico St. Cyr, a lawful resident alien from Haiti, was subject to deportation after pleading guilty to selling controlled substances. The legal complexities stemmed from two significant federal statutes, the Anti-terrorism and Effective Death Penalty Act (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), which limited the jurisdiction of federal courts in reviewing immigration decisions.
The Supreme Court's decision, rendered in a closely contested 5-4 ruling, confirmed that district courts maintain the authority to hear habeas corpus petitions from deportable aliens, despite the restrictions imposed by the new statutes. Justice John Paul Stevens highlighted the ambiguity in the statutory language, arguing that denying habeas corpus relief could raise constitutional concerns. Conversely, Justice Antonin Scalia dissented, asserting that habeas corpus was not a constitutionally guaranteed right and that the statutes explicitly removed jurisdiction from district courts. This case is significant as it underscores the balance between immigration enforcement and the legal rights of individuals facing deportation, reflecting ongoing debates about justice, legality, and human rights in the immigration system.
On this Page
Subject Terms
Immigration and Naturalization Service v. St. Cyr
The Case: U.S. Supreme Court decision on deportation procedures
Date: Decided on June 25, 2001
Significance:The St. Cyr decision held that recent federal legislation did not eliminate the federal courts’ jurisdiction to consider habeas corpus petitions from resident aliens who were deportable because of felony convictions.
In 1996, Enrico St. Cyr, a lawful resident alien from Haiti, pleaded guilty to selling controlled substances in Connecticut. As a result, immigration officials brought deportation proceedings against him. Two complex federal statutes of 1996, the Anti-terrorism and Effective Death Penalty Act (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), severely restricted the jurisdiction of the federal courts to exercise “judicial review” over immigration officials’ deportation proceedings and deportation orders. Despite the statutes, St. Cyr petitioned a U.S. district court for a writ of habeas corpus, and the petition was granted.
The major issue before the U.S. Supreme Court was whether the district courts continued to have habeas corpus jurisdiction over deportable aliens, as it did before enactment of the AEDPA and IIRIRA. In a 5-4 opinion, the Court ruled in the affirmative. Arguing that the relevant wording was ambiguous, Justice John Paul Stevens argued that the terms “judicial review” and “habeas corpus” had distinct legal meanings and that denial of the opportunity of habeas corpus relief would perhaps be unconstitutional. He wrote: “if an otherwise acceptable construction would raise serious constitutional problems and an alternative interpretation is fairly possible, the statute must be construed to avoid such problems.” In a strong dissent, Justice Antonin Scalia that the privilege of habeas corpus relief was not guaranteed in the U.S. Constitution and that the plain language of the two statutes stripped the district courts of jurisdiction to entertain petitions from deportable aliens.
Bibliography
Gordon, Charles, Stanley Mailman, and Stephen Yale-Loehr. Immigration Law and Procedure. New York: Matthew Bender, 2001.
Phelan, Margaret, and James Gillespie. Immigration Law Handbook. 2d ed. New York: Oxford University Press, 2005.