Salomon Ledezma-Cosino v. Loretta E. Lynch, 819 F.3d 1070

Petitioner Salomon Ledezma-Cosino, a Mexican national present in the U.S. since 1997, suffers from chronic alcoholism and has medical diagnoses including alcoholic hepatitis and cirrhosis; he has an alcohol-related DUI.
Ledezma sought cancellation of removal or voluntary departure; both reliefs require the applicant to demonstrate "good moral character" under 8 U.S.C. § 1101(f).
The BIA affirmed the Immigration Judge’s denial of relief solely on the ground that Ledezma is a "habitual drunkard" and thus lacks good moral character under § 1101(f)(1); the BIA declined to decide the constitutional challenge.
Ledezma raised constitutional claims arguing that classifying chronic alcoholism as evidence of bad moral character violates the Due Process and Equal Protection Clauses.
The Ninth Circuit held Ledezma could not press a due process challenge to discretionary relief (no protected liberty interest) but could press an equal protection challenge and ordered supplemental briefing on whether § 1101(f)(1) irrationally classifies a medical condition as moral blameworthiness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether classifying "habitual drunkards" as lacking good moral character violates Equal Protection	The statute irrationally equates chronic alcoholism (a medical disability) with bad moral character; the classification has no rational relation to the government interest	The statute targets conduct (habitual excessive drinking) and is rationally related to legitimate interests (public safety, burden on institutions); Congress may exclude classes of aliens	The court held § 1101(f)(1) unconstitutional under Equal Protection: medical disability (chronic alcoholism) is not rationally related to lacking moral character; statute vacated and remanded
Whether petitioner may raise a Due Process challenge to denial of discretionary relief	Ledezma argued denial based on an unconstitutional classification implicates due process	Government argued no protected liberty interest in discretionary relief, barring a due process claim	Court held petitioner lacks a protectable liberty interest in discretionary relief and cannot prevail on a due process claim; due process argument dismissed

City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (equal protection requires rational relation between classification and governmental objective)
Dada v. Mukasey, 554 U.S. 1 (2008) (benefits of voluntary departure and its significance to aliens)
Romer v. Evans, 517 U.S. 620 (1996) (animus is not a legitimate government interest under Equal Protection)
F.C.C. v. Beach Communications, 508 U.S. 307 (1993) (rational-basis review: upholding statutes if any conceivable rational basis exists)
Demore v. Kim, 538 U.S. 510 (2003) (Congress’s broad authority over immigration and exclusion of aliens)
Obergefell v. Hodges, 576 U.S. 644 (2015) (societal understanding can reveal unjustified inequalities)
Buck v. Bell, 274 U.S. 200 (1927) (historical context about past treatment of the mentally ill; cited for historical shift in constitutional attitudes)
Griffis v. Weinberger, 509 F.2d 837 (9th Cir. 1975) (recognition of chronic alcoholism as a disease)