Niz-Chavez v. Garland
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Niz-Chavez v. Garland and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Niz-Chavez v. Garland.
In Niz-Chavez v. Garland, the Supreme Court addressed whether a notice to appear under the Illegal Immigration Reform and Immigrant Responsibility Act must be a single document containing all required information. The Court ruled that the stop-time rule is triggered only by a single notice to appear, not multiple documents. This decision reversed the Sixth Circuit's ruling.
Holding
The single most important “bottom line” of what the Court decided in Niz-Chavez v. Garland.
The Court held that a notice to appear sufficient to trigger the IIRIRA's stop-time rule must be a single document containing all the information specified in § 1229(a)(1).
Constitutional Concepts
These are the Constitution-related themes that appear in Niz-Chavez v. Garland. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Niz-Chavez v. Garland
The case centers on whether the procedural requirements for a notice to appear were met, impacting the alien's right to fair procedures.
Syllabus excerpt (verbatim)A notice to appear sufficient to trigger the IIRIRA's stop-time rule is a single document containing all the information about an individual's removal hearing specified in § 1229(a)(1).
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Why Administrative Law is relevant to Niz-Chavez v. Garland
The case involves the interpretation of statutory requirements for agency action in issuing notices to appear, which is a matter of administrative law.
Syllabus excerpt (verbatim)The government claims that not knowing hearing officers' availability when it initiates removal proceedings makes it difficult to produce compliant notices.
Key Quotes
Short excerpts from the syllabus in Niz-Chavez v. Garland that support the summary and concepts above.
A notice to appear sufficient to trigger the IIRIRA's stop-time rule is a single document containing all the information about an individual's removal hearing specified in § 1229(a)(1).
Congress's decision to use the indefinite article 'a' suggests it envisioned 'a' single notice provided at a discrete time rather than a series of notices.
The modest threshold Congress provided to invoke the stop-time rule is clear from the text and must be complied with here.
