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Supreme Court decisions
No. 22-666Mar 19, 2024ImmigrationReversed

The question

Whether a court of appeals has jurisdiction under 8 U.S.C. 1252(a)(2)(D) to review an immigration judge's application of the "exceptional and extremely unusual hardship" standard when deciding a noncitizen's statutory eligibility for cancellation of removal.

Wilkinson v. Garland

What the Court decided

Reversed. Federal courts of appeals may review an immigration judge's application of the "exceptional and extremely unusual hardship" standard to a given set of facts when deciding a noncitizen's eligibility for cancellation of removal. The Third Circuit was wrong to hold it lacked jurisdiction. Applying that hardship standard to established facts is a mixed question of law and fact, and Section 1252(a)(2)(D) restores jurisdiction to review "questions of law," which includes such mixed questions.

How the justices split

6-3
In favor 6Against 3
Sotomayor
Kagan
Gorsuch
Kavanaugh
Barrett
Jackson
Roberts
Alito
Thomas

The Court's opinion

Sotomayor, joined by Kagan, Gorsuch, Kavanaugh, Barrett

The application of the statutory exceptional and extremely unusual hardship standard to a given set of facts is a mixed question of law and fact. Under Guerrero-Lasprilla v. Barr, Section 1252(a)(2)(D) restores jurisdiction over questions of law, which includes mixed questions, so the Third Circuit had jurisdiction to review the IJ's determination even though the underlying inquiry is fact-intensive.

Concurring in the judgment

Jackson, writing alone

Agreed with the outcome that the Third Circuit had jurisdiction to review the determination, but did not join the Court's reasoning.

Dissenting

Roberts, writing alone

Disagreed with the Court's conclusion that jurisdiction existed to review the IJ's hardship determination.

Dissenting

Alito, joined by Roberts, Thomas

Argued that the Court lacked jurisdiction to review the IJ's application of the hardship standard, contending the determination fell within the statute's bar on reviewing judgments regarding the granting of discretionary relief.

How we know · 5 sourced claims
  • The Third Circuit held it lacked jurisdiction under Section 1252(a)(2)(B)(i) to review the IJ's hardship determination.

    Source: syllabus, Held

  • Section 1252(a)(2)(D) restores jurisdiction to review questions of law, which under Guerrero-Lasprilla v. Barr includes mixed questions of law and fact.

    Source: syllabus, Held

  • Applying the exceptional and extremely unusual hardship standard to a given set of facts presents a mixed question of law and fact.

    Source: syllabus, Held

  • Sotomayor delivered the opinion of the Court, joined by Kagan, Gorsuch, Kavanaugh, and Barrett.

    Source: syllabus, lineup

  • Alito filed a dissenting opinion joined by Roberts and Thomas, and Roberts filed a separate dissent; Jackson concurred in the judgment.

    Source: syllabus, lineup

Read the opinion on supremecourt.gov