Patel v. Garland

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Supreme Court of the United States
Patel v. Garland
Term: 2021
Important Dates
Argued: December 6, 2021
Decided: May 16, 2022
Outcome
affirmed
Vote
5-4
Majority
Amy Coney Barrett • Chief Justice John G. Roberts • Clarence Thomas • Samuel Alito • Brett Kavanaugh
Dissenting
Neil Gorsuch • Stephen Breyer • Sonia Sotomayor • Elena Kagan

Patel v. Garland is a case that was decided by the Supreme Court of the United States on May 16, 2022, during the court's October 2021-2022 term. The case was argued before the court on December 6, 2021.

The court affirmed the decision of the United States Court of Appeals for the 11th Circuit in a 5-4 ruling, holding that federal courts do not have jurisdiction to review facts found during discretionary-relief proceedings under federal immigration law. Justice Amy Coney Barrett delivered the court's majority opinion. Justice Neil Gorsuch filed a dissent, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Pankajkumar Patel, an Indian citizen, entered the United States without being inspected. Because of this, he was given notice to appear at a removal hearing, after which an immigration judge recommended his deportation. The Board of Immigration Appeals (BIA) affirmed the judge's decision. On appeal to the U.S. Court of Appeals for the 11th Circuit, the court concluded that Congress removed federal courts’ jurisdiction to hear immigration appeals like the one at issue here, so the court was limited to reviewing the BIA’s legal conclusions only. After review by a panel and the en banc court, the 11th Circuit denied Patel’s petition for review.[2] Patel appealed to the U.S. Supreme Court. Click here to learn more about the case's background.
  • The issue: The case concerned the jurisdiction of federal courts to hear appeals in certain immigration proceedings.
  • The questions presented:

    1. "Whether 8 U.S.C. § 1252(a)(2)(B)(i) preserves the jurisdiction of federal courts to review a nondiscretionary determination that a noncitizen is ineligible for certain types of discretionary relief.
    2. Whether 8 U.S.C. § 1182(a)(6)(C)(ii), which renders a noncitizen inadmissible for 'falsely represent[ing]' oneself to be a U.S. citizen for a government benefit, applies to immaterial misrepresentations."[3]

    The court granted review limited to Question 1 only.

  • The outcome: The court affirmed the decision of the United States Court of Appeals for the 11th Circuit in a 5-4 ruling, holding that federal courts do not have jurisdiction to review facts found during discretionary-relief proceedings under federal immigration law.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 11th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Pankajkumar Patel, an Indian citizen, entered United States without being inspected. The Department of Homeland Security subsequently issued Patel a notice to appear in an immigration court and charged him with potential removable for being present in the U.S. without inspection. After a removal hearing, an immigration judge ordered Patel to be deported, and the Board of Immigration Appeals (BIA) affirmed the judge's decision. Patel filed a petition for review of the BIA's decision with the United States Court of Appeals for the 11th Circuit.[2]

    A three-judge panel of the 11th Circuit noted that Congress has "stripped our jurisdiction to hear certain appeals of immigration cases." Specifically, "Congress enumerated several '[m]atters not subject to judicial review' in 8 U.S.C. § 1252(a)(2). As it pertains to this case, we do not have 'jurisdiction to review ... any judgment regarding the granting of relief under section ... 1255 of this title.' § 1252(a)(2)(B). However, even when this jurisdictional bar applies, we still have power to review constitutional claims or questions of law. See § 1252(a)(2)(D). In short, we cannot review appeals from judgments under § 1255 unless the party raises a constitutional claim or a question of law." Accordingly, the 11th circuit concluded it could review the BIA's legal conclusions at issue, but it could not review the BIA's factual findings.[2]

    After reviewing the BIA's legal conclusions, the panel of the 11th Circuit found no grounds to overturn the BIA's findings and denied Patel's petition for review. Sitting en banc, the 11th Circuit also denied Patel's petition. Patel appealed to the U.S. Supreme Court.[2]

    Questions presented

    The petitioners presented the following questions to the court:[3]

    Questions presented:
    “ 1. Whether 8 U.S.C. § 1252(a)(2)(B)(i) preserves the jurisdiction of federal courts to review a nondiscretionary determination that a noncitizen is ineligible for certain types of discretionary relief.


    2. Whether 8 U.S.C. § 1182(a)(6)(C)(ii), which renders a noncitizen inadmissible for 'falsely represent[ing]' oneself to be a U.S. citizen for a government benefit, applies to immaterial misrepresentations.[4]

    		”


    The court granted review limited to Question 1 only.

    Oral argument

    The U.S. Supreme Court heard oral argument on December 6, 2021.

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    The court affirmed the decision of the United States Court of Appeals for the 11th Circuit in a 5-4 ruling, holding that federal courts do not have jurisdiction to review facts found during discretionary-relief proceedings under federal immigration law. Justice Amy Coney Barrett delivered the court's majority opinion. Justice Neil Gorsuch filed a dissent, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan.[1]

    Opinion

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

    “

    Congress has comprehensively detailed the rules by which noncitizens may enter and live in the United States. When noncitizens violate those rules, Congress has provided procedures for their removal. At the same time, there is room for mercy: Congress has given the Attorney General power to grant relief from removal in certain circumstances.

    Federal courts have a very limited role to play in this process. With an exception for legal and constitutional questions, Congress has barred judicial review of the Attorney General’s decisions denying discretionary relief from removal. We must decide how far this bar extends—specifically, whether it precludes judicial review of factual findings that underlie a denial of relief. It does.
    ...
    Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under §1255 and the other provisions enumerated in §1252(a)(2)(B)(i). We therefore affirm the judgment of the Court of Appeals.[4]

    		”
    —Justice Amy Coney Barrett

    Dissenting opinion

    Justice Gorsuch filed a dissenting opinion, joined by Justices Breyer, Sotomayor, and Kagan.

    In his dissent, Justice Gorsuch wrote:[1]

    “

    It is no secret that when processing applications, licenses, and permits the government sometimes makes mistakes. Often, they are small ones—a misspelled name, a misplaced application. But sometimes a bureaucratic mistake can have life-changing consequences. Our case is such a case. An immigrant to this country applied for legal residency. The government rejected his application. Allegedly, the government did so based on a glaring factual error. In circumstances like that, our law has long permitted individuals to petition a court to consider the question and correct any mistake.

    Not anymore. Today, the Court holds that a federal bureaucracy can make an obvious factual error, one that will result in an individual’s removal from this country, and nothing can be done about it. No court may even hear the case. It is a bold claim promising dire consequences for countless lawful immigrants. And it is such an unlikely assertion of raw administrative power that not even the agency that allegedly erred, nor any other arm of the Executive Branch, endorses it. Today’s majority acts on its own to shield the government from the embarrassment of having to correct even its most obvious errors. Respectfully, I dissent.[4]

    		”
    —Justice Neil Gorsuch

    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.[7]

    The court agreed to hear 68 cases during its 2021-2022 term.[8] Four cases were dismissed and one case was removed from the argument calendar.[9]

    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 1.4 U.S. Supreme Court, Patel v. Garland, decided May 16, 2022
    2. ↑ 2.0 2.1 2.2 2.3 U.S. Court of Appeals for the 11th Circuit, Patel v. U.S. Attorney General, decided March 6, 2019
    3. ↑ 3.0 3.1 U.S. Supreme Court, "No. 20-979: Question Presented," accessed June 28, 2021
    4. ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued December 6, 2021
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued December 6, 2021
    7. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    8. ↑ Consolidated cases are counted as one case for purposes of this number.
    9. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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