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Keywords

statuteappealhearingmotionwillfelonydeportationnaturalizationliens
statuteappealhearingwilldeportationnaturalizationliens

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Ranglin v. Reno

Facts

The petitioner, Donovan Silvester Ranglin, is a permanent resident alien who is subject to deportation because of his controlled substance conviction for possession with intent to deliver marijuana. Deportation proceedings were initiated against Ranglin on April 16, 1993, when the Immigration and Naturalization Services issued an Order to Show Cause. Ranglin admitted the factual allegations of his controlled substance conviction during the deportation hearing. The Immigration Judge found Ranglin deportable due to his conviction of a controlled substance violation and an aggravated felony. Ranglin filed a motion to reopen his case to apply for a waiver of deportation, which was granted, but his application was ultimately denied based on the AEDPA's restrictions.

The petitioner, Donovan Silvester Ranglin, is a permanent resident alien who is subject to deportation because of his controlled substance conviction for possession with intent to deliver marijuana. Deportation proceedings were initiated against Ranglin on April 16, 1993, when the Immigration and Naturalization Services issued an Order to Show Cause. Ranglin admitted the factual allegations of his controlled substance conviction during the deportation hearing.

Issue

Whether section 440(d) of the Anti-Terrorism and Effective Death Penalty Act (AEDPA) applies retroactively to aliens who were in deportation proceedings at the time of its enactment.

Whether section 440(d) of the Anti-Terrorism and Effective Death Penalty Act (AEDPA) applies retroactively to aliens who were in deportation proceedings at the time of its enactment.

Rule

There is a presumption against retroactivity in the application of statutes, and a statute will not be applied retroactively unless there is clear congressional intent to do so.

There is a presumption against retroactivity in the application of statutes, and a statute will not be applied retroactively unless there is clear congressional intent to do so.

Analysis

The court applied the rule of presumption against retroactivity to the facts of Ranglin's case, determining that the application of AEDPA 440(d) would impair Ranglin's substantive rights. The court referenced the First Circuit's reasoning in Goncalves v. Reno, which concluded that Congress did not intend for the new provisions restricting discretionary relief to apply retroactively. The court found that the legislative history and the lack of explicit language regarding retroactive application supported the conclusion that AEDPA 440(d) should not apply to pending deportation cases.

The court applied the rule of presumption against retroactivity to the facts of Ranglin's case, determining that the application of AEDPA 440(d) would impair Ranglin's substantive rights. The court referenced the First Circuit's reasoning in Goncalves v. Reno, which concluded that Congress did not intend for the new provisions restricting discretionary relief to apply retroactively.

Conclusion

The court remanded the case to the Board of Immigration Appeals for a discretionary determination of the merits of the alien's application for relief from deportation.

The court remanded the case to the Board of Immigration Appeals for a discretionary determination of the merits of the alien's application for relief from deportation.

Who won?

Ranglin prevailed in the case because the court found that the AEDPA's restrictions did not apply retroactively to his situation, allowing him to seek relief from deportation.

Ranglin prevailed in the case because the court found that the AEDPA's restrictions did not apply retroactively to his situation, allowing him to seek relief from deportation.

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