Immigration and Naturalization Service v. St. Cyr
|INS v. St. Cyr|
|Argued April 24, 2001|
Decided June 25, 2001
|Full case name||Immigration and Naturalization Service v. Enrico St. Cyr|
|Citations||533 U.S. 289 (more)|
|Prior history||Dunbar 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)|
|The Antiterrorism and Effective Death Penalty act of 1996 (AEDPA) and Illegal Immigration Reform and Immigration Responsibility act of 1996 (IIRIRA) did not deny district courts their jurisdiction under the general habeas corpus statute.|
|Majority||Stevens, joined by Kennedy, Souter, Ginsburg, Breyer|
|Dissent||Scalia, joined by Rehnquist, Thomas; O'Connor (parts I and III)|
|28 U.S.C. §§ 2241–2255|
Enrico St. Cyr pleaded guilty to a controlled substance 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.
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 § 212(c) of the INA to aliens who would have been eligible for such relief at the time of their convictions?
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 § 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.
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.