Santos-Zacaria v. Garland
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Santos-Zacaria 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 Santos-Zacaria v. Garland.
In Santos-Zacaria v. Garland, the Supreme Court addressed whether the exhaustion requirement under 8 U.S.C. § 1252(d)(1) is jurisdictional. The Court determined that this requirement is not jurisdictional and does not mandate noncitizens to seek discretionary forms of review, such as reconsideration by the Board of Immigration Appeals. The decision vacated part of the Fifth Circuit's ruling and remanded the case.
Holding
The single most important “bottom line” of what the Court decided in Santos-Zacaria v. Garland.
The Court held that Section 1252(d)(1)'s exhaustion requirement is not jurisdictional and does not require noncitizens to request discretionary forms of review.
Constitutional Concepts
These are the Constitution-related themes that appear in Santos-Zacaria v. Garland. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Santos-Zacaria v. Garland
The case deals with the interpretation of statutory exhaustion requirements and their jurisdictional nature, which involves constitutional limits on agency authority.
Syllabus excerpt (verbatim)Section 1252(d)(1)'s exhaustion requirement is not jurisdictional.
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Why Judicial Review is relevant to Santos-Zacaria v. Garland
The case involves the court's power to review agency decisions and the conditions under which such review is permissible.
Syllabus excerpt (verbatim)A court may review a final order of removal only if... the alien has exhausted all administrative remedies available to the alien as of right.
Key Quotes
Short excerpts from the syllabus in Santos-Zacaria v. Garland that support the summary and concepts above.
Section 1252(d)(1)'s exhaustion requirement is not jurisdictional.
Section 1252(d)(1) does not require noncitizens to request discretionary forms of review.
Exhaustion requirements are quintessential claim-processing rules, designed to promote efficiency in litigation.
