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Garland v. Gonzalez

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Supreme Court of the United States
Garland v. Gonzalez
Term: 2021
Important Dates
Argued: January 11, 2022
Decided: June 13, 2022
Outcome
Reversed and remanded
Vote
6-3
Majority
Samuel Alito • Chief Justice John G. Roberts • Clarence Thomas • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Sonia Sotomayor (in the judgment)
Dissenting
Sonia Sotomayor (in part) • Elena Kagan • Stephen Breyer

Garland v. Gonzalez is a case that was decided by the Supreme Court of the United States on June 13, 2022, during the court's October 2021-2022 term. The case was argued before the court on January 11, 2022.

The court reversed and remanded the decision of the United States Court of Appeals for the 9th Circuit in a 6-3 ruling, holding that Section 1252(f )(1) of the Immigration and Nationality Act (INA) deprived the federal district courts of jurisdiction to consider respondents’ requests for class-wide injunctive relief.[1] Justice Samuel Alito delivered the court's majority opinion. Justice Sonia Sotomayor filed an opinion concurring in the judgment in part and dissenting in part. Sotomayor's dissenting opinion was joined by Justice Elena Kagan and in part by Justice Stephen Breyer. Click here for more information about the ruling.

HIGHLIGHTS
  • The case: The plaintiffs in this case are non-U.S. citizens subject to a removal order who have been in immigration detention for six or more months. The detainees brought suit against the U.S. government challenging their continued detainment without a bond hearing. The federal district courts found for the detainees, holding that the 9th Circuit's ruling in Diouf v. Napolitano required that detainees held for six months or more are entitled to a bond hearing before an immigration judge. On appeal, the 9th Circuit affirmed.[2][3] Click here to learn more about the case's background.
  • The issue: The case concerned the right of non-citizens in immigration detention to a bond hearing and the jurisdiction of federal courts to grant class-wide injunctive relief in such cases.
  • The questions presented:[4]

    1. "Whether an alien who is detained under 8 U.S.C. 1231 is entitled by statute, after six months of detention, to a bond hearing at which the government must prove to an immigration judge that the alien is a flight risk or a danger to the community.
    2. Whether, under 8 U.S.C. § 1252 (f) (1), the courts below had jurisdiction to grant classwide injunctive relief."[5]

  • The outcome: The court reversed and remanded the decision of the United States Court of Appeals for the 9th Circuit in a 6-3 ruling.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. To review the 9th Circuit's opinion in Gonzalez v. Barr click here, and in Tejada v. Godfrey here.

    Timeline

    The following timeline details key events in this case:

    Background

    This appeal to the Supreme Court involves two cases originating from the United States Court of Appeals for the 9th Circuit: Gonzalez v. Barr and Tejada v. Godfrey. The acting U.S. solicitor general filed one petition for a writ of certiorari pursuant to a Supreme Court rule that a single petition can be filed when the judgments to be reviewed are from "the same court and involve identical or closely related questions."[6]

    The plaintiff-respondents in both cases are non-U.S. citizens who are in immigration detention with orders of removal pursuant to 8 U.S. Code § 1231, which relates to the detention and removal of non-citizens ordered removed. The non-citizens were in detention for six months or longer and brought suits against the U.S. government challenging the government's right to continue holding them without individualized bond hearings before an immigration judge. The district courts found for the plaintiffs, ruling that they were bound by the U.S. Court of Appeals for the 9th Circuit's holding in Diouf v. Napolitano (2011) that non-citizen detainees held for six months or longer are statutorily entitled to a bond hearing in front of an immigration judge.[2][3] On appeal, the 9th Circuit affirmed the rulings. The U.S. government appealed to the Supreme Court.

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    “ 1. Whether an alien who is detained under 8 U.S.C. 1231 is entitled by statute, after six months of detention, to a bond hearing at which the government must prove to an immigration judge that the alien is a flight risk or a danger to the community.


    2. Whether, under 8 U.S.C. § 1252 (f) (1), the courts below had jurisdiction to grant classwide injunctive relief.[7][8]

    		”

    Oral argument

    Audio

    Audio of oral argument:[9]



    Transcript

    Transcript of oral argument:[10]

    Outcome

    The court reversed and remanded the decision of the United States Court of Appeals for the 9th Circuit in a 6-3 ruling, holding that Section 1252(f )(1) of the Immigration and Nationality Act (INA) deprived the federal district courts of jurisdiction to consider respondents’ requests for class-wide injunctive relief.[1] Justice Samuel Alito delivered the court's majority opinion. Justice Sonia Sotomayor filed an opinion concurring in the judgment in part and dissenting in part. Sotomayor's dissenting opinion was joined by Justice Elena Kagan and in part by Justice Stephen Breyer.

    Opinion

    In the court's majority opinion, Justice Samuel Alito wrote:[1]

    “ Respondents in these two cases are aliens who were detained by the Federal Government pursuant to 8 U.S.C. §1231(a)(6) pending removal from this country. Respondents sued in two Federal District Courts, alleging that §1231(a)(6) requires the Government to provide bond hearings in cases like theirs. Both District Courts certified classes, agreed with respondents’ claims on the merits, and entered class-wide injunctive relief. The Ninth Circuit affirmed both judgments in relevant part.


    We granted certiorari and instructed the parties to address whether another provision of the Immigration and Nationality Act, 66 Stat. 208, as amended, 8 U.S.C. §1252(f )(1), deprived the District Courts of jurisdiction to entertain respondents’ requests for class-wide injunctive relief. We hold that the statute has that effect, and we therefore reverse.[8]

    		”
    —Justice Samuel Alito

    Concurring in part, dissenting in part

    Justice Sonia Sotomayor filed an opinion concurring in the judgment in part and dissenting in part. Sotomayor's dissenting opinion was joined by Justice Elena Kagan and in part by Justice Stephen Breyer.

    In her concurring opinion, Justice Sotomayor wrote:[1]

    “ The Court holds that lower federal courts are powerless to issue classwide injunctive relief against the Executive Branch’s violation of noncitizens’ rights under several provisions of the Immigration and Nationality Act (INA). It reaches this conclusion in a purportedly textualist opinion that, in truth, elevates piecemeal dictionary definitions and policy concerns over plain meaning and context. I respectfully dissent from the Court’s blinkered analysis, which will leave many vulnerable noncitizens unable to protect their rights.[8] ”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]

    The court agreed to hear 68 cases during its 2021-2022 term.[12] Four cases were dismissed and one case was removed from the argument calendar.[13]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Garland v. Gonzalez, decided June 13, 2022
    2. ↑ 2.0 2.1 United States Court of Appeals for the 9th Circuit, Gonzalez v. Barr, decided April 7, 2020
    3. ↑ 3.0 3.1 United States Court of Appeals for the 9th Circuit, Tejada v. Godfrey, decided April 7, 2020
    4. ↑ 4.0 4.1 U.S. Supreme Court, "No. 20-322: Question Presented," accessed August 23, 2021
    5. ↑ Note: Question 2 was not included in the petition for a writ of certiorari; in its grant, the U.S. Supreme Court directed the parties to brief and argue the question.
    6. ↑ U.S. Supreme Court, "Barr v. Gonzalez/Barr v. Tejada: On Petition For Writ Of Certiorari To The United States Court Of Appeals For The Ninth Circuit," filed January 17, 2020
    7. ↑ Note: Question 2 was not included in the petition for a writ of certiorari; in its grant, the U.S. Supreme Court directed the parties to brief and argue the question.
    8. ↑ 8.0 8.1 8.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 11, 2022
    10. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 11, 2022
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    12. ↑ Consolidated cases are counted as one case for purposes of this number.
    13. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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