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Keywords

attorneyappealhearingleaseregulationdue processdeportationnaturalizationrespondentliens

appealhearingleaseregulationdue processdeportationnaturalizationrespondentliens

Related Cases

Reno v. Flores, 507 U.S. 292, 113 S.Ct. 1439, 123 L.Ed.2d 1, 61 USLW 4237

Facts

Respondents are a class of alien juveniles arrested by the INS on suspicion of being deportable and detained pending deportation hearings. They challenged a regulation that allowed their release only to parents, close relatives, or legal guardians, arguing they had a constitutional right to be released into the custody of other responsible adults. The District Court invalidated the regulation on due process grounds, leading to an appeal and subsequent en banc review by the Ninth Circuit, which affirmed the lower court's decision.

Respondents are a class of alien juveniles arrested by the Immigration and Naturalization Service (INS) on suspicion of being deportable, and then detained pending deportation hearings pursuant to a regulation, 1442 promulgated in 1988 and codified at 8 CFR § 242.24, which provides for the release of detained minors only to their parents, close relatives, or legal guardians, except in unusual and compelling circumstances.

Issue

Did the INS regulation limiting the release of detained juvenile aliens to parents, close relatives, or legal guardians violate their substantive and procedural due process rights?

Rule

The regulation does not violate the Due Process Clause as it does not deprive respondents of substantive due process, and existing INS procedures provide alien juveniles with procedural due process.

1. Because this is a facial challenge to the regulation, respondents must establish that no set of circumstances exists under which the regulation would be valid.

Analysis

The Supreme Court found that the regulation was rationally connected to the government's interest in the welfare of detained juveniles and did not constitute punishment. The Court also determined that the procedures in place allowed for sufficient due process, as the juveniles had the right to request a review of their custody status, and there was no evidence that they were unable to exercise that right.

The regulation does not deprive respondents of 'substantive due process.' The substantive right asserted by respondents is properly described as the right of a child who has no available parent, close relative, or legal guardian, and for whom the government is responsible, to be placed in the custody of a private custodian rather than of a government-operated or government-selected child-care institution.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the INS regulation was constitutional and within the scope of the Attorney General's discretion.

Judgment of Court of Appeals reversed and remanded.

Who won?

The prevailing party was the Immigration and Naturalization Service (INS), as the Supreme Court ruled in favor of the regulation limiting the release of juvenile aliens.

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