604 U.S. 670
SCOTUS2025Background
- President Trump invoked the Alien Enemies Act (AEA) to detain and remove Venezuelan nationals alleged to be members of the Tren de Aragua (TdA), now considered a foreign terrorist organization.
- Five detainees and a putative class sought injunctive relief, challenging the Proclamation and their imminent removal without due process, originally filing in the District of Columbia.
- The District Court issued temporary restraining orders (TROs) halting removals under the Proclamation while granting provisional class certification.
- The government sought emergency relief, arguing TROs were improper and that all such challenges must be brought via habeas in the district of confinement (Texas, not D.C.).
- The Supreme Court, in a per curiam opinion, vacated the TROs, holding venue and procedural defects warranted government relief, but noted detainees must receive notice and an opportunity to challenge removal.
- Dissents strongly criticized the government’s conduct and the majority’s rush to decide, warning of due process violations and grave harm to detainees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper procedural vehicle | Class APA/injunctive relief in D.C. is proper; not seeking release | Only habeas petitions (not APA/class actions) available | Must be brought in habeas; APA not available |
| Venue for challenge | D.C. is proper due to national policy and class issues | Venue proper only in district of confinement (Texas) | Venue is district of confinement |
| Due process before removal | Summary removal violates due process; no notice/opportunity to be heard | AEA allows removal; judicial review is limited or excluded | Due process requires notice and chance to seek habeas prior to removal |
| Authority for removal under AEA | AEA does not apply; no war/invasion; improper use against criminal group | Proclamation valid; TdA is a qualifying threat under AEA | Substantive challenge not reached (procedural grounds ruled) |
Key Cases Cited
- Ludecke v. Watkins, 335 U.S. 160 (1948) (alien enemy removal under AEA precludes general judicial review, but allows habeas and constitutional questions)
- Carson v. American Brands, Inc., 450 U.S. 79 (1981) (appealability of injunctive orders and TROs)
- Heikkila v. Barber, 345 U.S. 229 (1953) (habeas as the sole vehicle for certain immigration detention challenges)
- Nance v. Ward, 597 U.S. 159 (2022) (core habeas petition includes claims implying the invalidity of confinement)
- Heck v. Humphrey, 512 U.S. 477 (1994) (habeas exclusivity principle for claims implying invalidity of confinement or sentence)
- Reno v. Flores, 507 U.S. 292 (1993) (aliens have due process rights in removal proceedings)
- Peyton v. Rowe, 391 U.S. 54 (1968) (habeas corpus remedies not limited to immediate release)
- Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (due process requires notice and opportunity to be heard)
- Rumsfeld v. Padilla, 542 U.S. 426 (2004) (habeas corpus venue is district of confinement)