View source for Immigration and Naturalization Service v. St. Cyr

{{Use mdy dates|date=September 2023}}
{{Primary sources|date=January 2020}}
{{Infobox SCOTUS case
  |Litigants=INS v. St. Cyr
  |ArgueDate=April 24
  |ArgueYear=2001
  |DecideDate=June 25
  |DecideYear=2001
  |FullName= Immigration and Naturalization Service v. Enrico St. Cyr
  |USVol= 533
  |USPage= 289
  |ParallelCitations=121 S. Ct. 2271; 150 [[L. Ed. 2d]] 347, 2001 [[U.S. LEXIS]] 4670 
  |Prior= ''Dunbar v. INS'', 64 [[F. Supp. 2d]] [https://law.justia.com/cases/federal/district-courts/FSupp2/64/47/2578585/ 47] ([[D. Conn.]] 1999); aff'd sub nom., ''St. Cyr v INS'', 229 [[F.3d]] [https://law.justia.com/cases/federal/appellate-courts/F3/229/406/577482/ 406] ([[2d Cir.]] 2000); [[Certiorari|cert]]. granted, {{ussc|531|1107|2001|el=no}}.
  |Subsequent= 
  |Holding= {{ordered list
  |style=text-align: left;
   |1=[[Antiterrorism and Effective Death Penalty Act of 1996|AEDPA]] and [[Illegal Immigration Reform and Immigrant Responsibility Act of 1996|IIRIRA]] did not divest [[United States district court|district courts]] of their jurisdiction under the general habeas corpus statute.
   |2=Aliens who pleaded guilty to criminal charges that rendered them deportable prior to the effective date of [[Antiterrorism and Effective Death Penalty Act of 1996|AEDPA]] and [[Illegal Immigration Reform and Immigrant Responsibility Act of 1996|IIRIRA]] remain eligible for discretionary relief from deportation.
  }}
  |Majority=Stevens
  |JoinMajority=Kennedy, Souter, Ginsburg, Breyer
  |Dissent=O'Connor
  |Dissent2=Scalia
  |JoinDissent2=Rehnquist, Thomas; O'Connor (Parts I and III)
  |LawsApplied={{usc|28|2241|2255}}
}}
'''''Immigration and Naturalization Service v. St. Cyr''''', 533 U.S. 289 (2001), is a [[United States]] [[Supreme Court of the United States|Supreme Court]] case involving [[habeas corpus]] and [[Immigration and Nationality Act|INA]] § 212(c) relief (repealed 1997) for deportable [[alien (law)#United States|aliens]].

== Facts ==
Enrico St. Cyr, a Haitian citizen, had been a [[lawful permanent residents (United States)|lawful permanent resident]] (LPR) of the United States for ten years when he pleaded guilty to a [[controlled substance]] violation in [[Connecticut]]. Under the [[Immigration and Nationality Act]] (INA), St. Cyr became "removable" after he was convicted of a controlled substance violation.<ref name=removable>{{uscsub|8|1229a|e|2}} ("The term 'removable' means—(A) in the case of an [[alien (law)#United States|alien]] not admitted to the United States, that the alien is inadmissible under section 1182 of this title, or (B) in the case of an alien admitted to the United States, that the alien is deportable under section 1227 of this title."); see also ''Tima v. Attorney General of the U.S.'', 903 [[F.3d]] [https://www.leagle.com/decision/infco20180906085 272], 277 ([[United States Court of Appeals for the Third Circuit|3d Cir.]] 2018); {{cite court |litigants=Galindo v. Sessions |vol=897 |reporter=F.3d |opinion=894 |pinpoint=897 |court=[[United States Court of Appeals for the Seventh Circuit|7th Cir.]] |date=2018 |url=https://www.leagle.com/decision/infco20180731210 |accessdate=2020-01-12 |quote=}}</ref> Before the [[Antiterrorism and Effective Death Penalty Act of 1996]] (AEDPA)<ref name=AEDPA>[[Antiterrorism and Effective Death Penalty Act of 1996]], {{USStatute|104|132|110|1214}}.</ref> and the [[Illegal Immigration Reform and Immigrant Responsibility Act of 1996]] (IIRIRA),<ref name=IIRIRA>[[Illegal Immigration Reform and Immigrant Responsibility Act of 1996]], {{USStatute|104|208|110|3009-546}}, Div. C.</ref> INA § 212(c) was interpreted to give the [[United States Attorney General|U.S. Attorney General]] broad discretion to waive deportation of certain LPRs. The AEDPA and IIRIRA, however, limited relief{{clarify|reason=habeas relief?|date=January 2023}} to LPRs and non-LPRs. U.S. Attorney General [[John Ashcroft]] argued that AEDPA and IIRIRA stripped him of the authority to grant St. Cyr any waiver. St. Cyr, who had pleaded guilty on March 8, 1996, which was prior to the enactment of AEDPA and IIRIRA, had [[removal proceedings]] brought against him on April 10, 1997, after the enactment of these Acts, conceded removability but argued that he was entitled to a writ of habeas corpus. The [[United States District Court for the District of Connecticut|U.S. District for the District of Connecticut]] accepted St. Cyr's habeas corpus application and agreed that the new restrictions do not apply to removal proceedings brought against an LPR who pleaded guilty to a deportable crime before the enactment of AEDPA and IIRIRA.<ref>{{cite court |litigants=Dunbar v. INS |vol=64 |reporter=F. Supp. 2d |opinion=47 |pinpoint= |court=[[D. Conn.]] |date=1999 |url=https://law.justia.com/cases/federal/district-courts/FSupp2/64/47/2578585/ |accessdate=2020-01-12 |quote=}}</ref> The [[United States Court of Appeals for the Second Circuit|U.S. Court of Appeals for the Second Circuit]] affirmed.<ref>{{cite court |litigants=St. Cyr v. INS |vol=229 |reporter=F.3d |opinion=406 |pinpoint= |court=[[2d Cir.]] |date=2000 |url=https://law.justia.com/cases/federal/appellate-courts/F3/229/406/577482/ |accessdate=2020-01-12 |quote=}}</ref>

== Issues ==
The Supreme Court answered two questions. The first one was procedural. Do the AEDPA and IIRIRA strip [[United States district court|federal district courts]] of habeas corpus jurisdiction over deportable aliens as previously granted under {{usc|28|2241}}? The substantive question was whether the federal laws deny relief under INA § 212(c) to LPRs who would have been eligible for such relief at the time of their convictions?

== Decision ==
In a 5-4 opinion, [[John Paul Stevens|Justice John Paul Stevens]] wrote for the majority stating that [[United States Congress|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 relief under INA § 212(c) to LPRs who would have been eligible for such relief at the time of their convictions.<ref name=opinion>{{ussc|name=Immigration and Naturalization Service v. St. Cyr|volume=533|page=289|pin=|year=2001}}.</ref> Stevens reasoned that the Supreme Court should interpret statutes as avoiding [[United States Constitution|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 of the U.S. Constitution|Article III]] federal courts.

== Dissent ==
[[Antonin Scalia|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.

==See also==
*[[List of United States Supreme Court cases, volume 533]]
*[[List of United States Supreme Court cases]]

== References ==
{{Reflist}}

==External links==
* {{caselaw source
 | case = ''Immigration and Naturalization Service v. St. Cyr'', {{ussc|533|289|2001|el=no}}
 | courtlistener =https://www.courtlistener.com/opinion/118452/ins-v-st-cyr/
 | findlaw = https://caselaw.findlaw.com/us-supreme-court/533/289.html
 | justia =https://supreme.justia.com/cases/federal/us/533/289/case.html
 | loc =http://cdn.loc.gov/service/ll/usrep/usrep533/usrep533289/usrep533289.pdf
 | oyez =https://www.oyez.org/cases/2000/00-767
 | other_source1 = Casetext
 | other_url1 =https://casetext.com/case/immigration-naturalization-service-v-st-cyr
 }}
* [https://www.uscis.gov/i-191 I-191, Application for Relief Under Former Section 212(c) of the Immigration and Nationality Act (INA)]

{{USArticleI}}

[[Category:United States Constitution Article One case law]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court cases of the Rehnquist Court]]
[[Category:United States immigration and naturalization case law]]
[[Category:Suspension Clause case law]]
[[Category:2001 in United States case law]]
[[Category:Deportation from the United States]]
[[Category:Haiti–United States relations]]