Immigration and Naturalization Service v. St. Cyr Summary

  • Last updated on November 10, 2022

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 [a]Anti-terrorism and Effective Death Penalty Act of 1996[Antiterrorism and Effective Death Penalty Act]Anti-terrorism and Effective Death Penalty Act (AEDPA) and the [a]Illegal Immigration Reform and Immigrant Responsibility Act of 1996Illegal Immigration Reform and 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.[c]Immigration and Naturalization Service v. St. CyrDeportation;Immigration and Naturalization Service v. St. CyrHabeas corpusSt. Cyr, Enrico[c]Immigration and Naturalization Service v. St. CyrDeportation;Immigration and Naturalization Service v. St. CyrHabeas corpusSt. Cyr, Enrico[cat]COURT CASES;Immigration and Naturalization Service v. St. Cyr[02700][cat]DEPORTATION;Immigration and Naturalization Service v. St. Cyr[02700]

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 Stevens, John PaulJohn 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 Scalia, AntoninAntonin 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.[c]Immigration and Naturalization Service v. St. CyrDeportation;Immigration and Naturalization Service v. St.CyrHabeas corpusSt. Cyr, Enrico

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.

Citizenship

Congress, U.S.

Constitution, U.S.

Deportation

Immigration law

Supreme Court, U.S.
Categories: History