Reyes Mata v. Lynch
135 S. Ct. 2150
| SCOTUS | 2015Background
- Noel Reyes Mata, a Mexican national, was ordered removed after a criminal conviction; his appeal to the BIA was dismissed after his first attorney failed to file a brief.
- Mata filed a motion to reopen with the BIA more than 90 days after the final order, seeking equitable tolling for his attorney’s misconduct.
- The BIA held it could equitably toll in principle but denied relief to Mata for lack of prejudice and found the motion untimely; it also declined to reopen sua sponte.
- Mata appealed to the Fifth Circuit, which treated his equitable-tolling request as a request for the BIA to reopen sua sponte and dismissed for lack of jurisdiction (the Fifth Circuit holds it cannot review sua sponte denials).
- The Supreme Court granted certiorari to resolve a circuit split over whether courts of appeals have jurisdiction to review BIA denials of motions to reopen that are based on timeliness/equitable tolling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether courts of appeals have jurisdiction to review BIA denials of motions to reopen that are dismissed as untimely or for denying equitable tolling | Mata: Courts have jurisdiction under 8 U.S.C. § 1252, as reaffirmed in Kucana, to review BIA denials of motions to reopen including timeliness/equitable tolling denials | Government (and Fifth Circuit recharacterization): Treat such requests as invitations to exercise sua sponte authority, which courts generally cannot review, so the appeals court lacked jurisdiction | The Court held courts of appeals do have jurisdiction to review BIA denials of statutory motions to reopen regardless of the reason (including untimeliness/equitable-tolling denials) and reversal of the Fifth Circuit was required |
| Whether recharacterizing a petitioner’s timely-labeled motion for equitable tolling as a sua sponte request is permissible to avoid jurisdiction | Mata: Recharacterization that strips jurisdiction is improper; courts should take jurisdiction and decide the merits | Amicus/Fifth Circuit: Courts sometimes recharacterize filings to identify available relief; if equitable tolling is categorically unavailable, recharacterization is warranted | The Court rejected recharacterization as a jurisdictional dodge; courts must assert jurisdiction and resolve the merits rather than recast claims to avoid review |
| Whether this decision decides whether equitable tolling is available under the INA | Mata: Equitable tolling may be available in certain exceptional circumstances | Government/Amicus: Argued the INA may categorically preclude tolling (position assumed for argument) | The Court expressly declined to decide whether or when equitable tolling is available under the INA; it limited its ruling to jurisdictional authority |
Key Cases Cited
- Kucana v. Holder, 558 U.S. 233 (recognizing courts of appeals' jurisdiction to review BIA denials of motions to reopen)
- Dada v. Mukasey, 554 U.S. 1 (recognizing statutory right to file one motion to reopen)
- Steel Co. v. Citizens for Better Environment, 523 U.S. 83 (distinguishing jurisdictional and merits questions)
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (federal courts' obligation to exercise jurisdiction)
- Castro v. United States, 540 U.S. 375 (distinguishing construing filings from recharacterization)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (party asserting federal jurisdiction bears burden)