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 Reformand 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.

Thomas Tandy Lewis

Further Reading

• 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. 

See also: Citizenship; Congress, U.S.; Constitution, U.S.; Deportation; Due process protections; Immigration law; Supreme Court, U.S.