Garland v. Gonzalez
596 U.S. 543
SCOTUS2022Background
- Plaintiffs (named in two consolidated cases) are noncitizens detained under 8 U.S.C. §1231(a)(6) after illegal reentry and reinstatement of prior removal orders; they sought withholding of removal while detained.
- Each plaintiff filed a putative class action challenging prolonged detention without bond hearings, arguing §1231(a)(6) requires hearings after six months.
- Two district courts certified classes and entered class‑wide injunctions requiring individualized bond hearings (every 180 days); Ninth Circuit panels affirmed in divided decisions.
- The Government petitioned, and the Supreme Court granted certiorari limited to whether 8 U.S.C. §1252(f)(1) deprived lower courts of jurisdiction to grant class‑wide injunctive relief.
- The Supreme Court held §1252(f)(1) strips the district courts of jurisdiction to issue the class‑wide injunctive relief that was awarded in these cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1252(f)(1) bar lower courts from issuing class‑wide injunctions that "enjoin or restrain the operation of" Part IV of the INA (including §1231(a)(6))? | Plaintiffs: §1252(f)(1) does not bar class relief that enforces statutes or remedies unlawful agency action; the prefatory language and Califano support class adjudication. | Government: §1252(f)(1) plainly removes jurisdiction to "enjoin or restrain the operation of" listed INA provisions, so class‑wide injunctions are forbidden. | Held for Government: §1252(f)(1) deprives lower courts of jurisdiction to grant class‑wide injunctive relief under the statute. |
| Does "enjoin or restrain the operation of" include injunctions that compel the Government to comply with the statute (i.e., enjoin unlawful agency implementation)? | Plaintiffs/Dissent: "Operation" = statute's functioning; injunctions forcing compliance do not "restrain" operation because unlawful implementation is not the statute's operation. | Government/Majority: "Operation" encompasses the Government's enforcement/implementation (lawful or unlawful); injunctions ordering or forbidding official actions interfere with that operation. | Held for Government: "operation" covers the Government's implementation/enforcement, so injunctions directing official conduct to change practices qualify as restraining operation. |
| Does the saving clause "with respect to the application of such provisions to an individual alien" permit class‑wide relief for individuals in proceedings? | Plaintiffs: A class is just many individual claims; the saving clause allows relief for members who are individuals in proceedings (and Califano shows "individual" does not bar class relief). | Government: "an individual alien" (singular) limits relief to individualized, non‑class relief. | Held for Government: The exception does not authorize class‑wide injunctive relief; relief limited to individualized orders. (Dissent disagreed.) |
Key Cases Cited
- Nken v. Holder, 556 U.S. 418 (2009) (definition and function of injunctions discussed).
- Reno v. American‑Arab Anti‑Discrimination Comm., 525 U.S. 471 (1999) (stated §1252(f)(1) prohibits federal courts from granting classwide injunctive relief but not individual relief).
- Direct Marketing Assn. v. Brohl, 575 U.S. 1 (2015) (explains that "restrain" can have broad or narrower meanings in judicial contexts).
- Califano v. Yamasaki, 442 U.S. 682 (1979) (statutory authorization for review of "any individual" does not automatically preclude class actions or class relief).
- Merck & Co. v. Reynolds, 559 U.S. 633 (2010) (courts presume Congress knows relevant precedent when enacting statutes).
- McQuiggin v. Perkins, 569 U.S. 383 (2013) (courts will not displace traditional equitable authority absent a clear command).
- Porter v. Warner Holding Co., 328 U.S. 395 (1946) (historical recognition of federal equitable powers).