Pugin v. Garland
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Pugin 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 Pugin v. Garland.
In Pugin v. Garland, the Supreme Court addressed whether an offense can relate to obstruction of justice under 8 U.S.C. § 1101(a)(43)(S) without a pending investigation or proceeding. The Court affirmed the Fourth Circuit's decision and reversed the Ninth Circuit's, concluding that such offenses can indeed relate to obstruction of justice. The decision impacts the removability of noncitizens with convictions for aggravated felonies.
Holding
The single most important “bottom line” of what the Court decided in Pugin v. Garland.
The Court held that an offense may relate to obstruction of justice under § 1101(a)(43)(S) even if no investigation or proceeding is pending.
Constitutional Concepts
These are the Constitution-related themes that appear in Pugin 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 Pugin v. Garland
The case involves the interpretation of statutory language affecting the removal of noncitizens, which implicates procedural due process in the context of immigration proceedings.
Syllabus excerpt (verbatim)Federal law provides that noncitizens convicted of a federal or state crime constituting an 'aggravated felony' are removable from the United States.
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Why Judicial Review is relevant to Pugin v. Garland
The Court's decision involves interpreting federal statutes and reviewing lower court decisions, which is a function of judicial review.
Syllabus excerpt (verbatim)The Court declines to adopt an interpretation of the statute that would exclude many common obstruction offenses from the definition of aggravated felony under § 1101(a)(43)(S).
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Why Void for Vagueness is relevant to Pugin v. Garland
The case involves interpreting the scope of 'relating to obstruction of justice,' which could raise concerns about vagueness in statutory language.
Syllabus excerpt (verbatim)The phrase 'relating to' resolves any doubt about the scope of § 1101(a)(43)(S), because it ensures that the statute covers offenses having a connection with obstruction of justice.
Key Quotes
Short excerpts from the syllabus in Pugin v. Garland that support the summary and concepts above.
An offense may 'relat[e] to obstruction of justice' under § 1101(a)(43)(S) even if the offense does not require that an investigation or proceeding be pending.
Federal law provides that noncitizens convicted of a federal or state crime constituting an 'aggravated felony' are removable from the United States.
The phrase 'relating to' resolves any doubt about the scope of § 1101(a)(43)(S).
