## Facts

- Enrico St. Cyr, a Haitian citizen and lawful permanent resident, pleaded guilty in Connecticut state court on March 8, 1996 to selling a controlled substance, making him deportable under the INA.
- At the time of the plea, former INA § 212(c) allowed the Attorney General discretionary relief from deportation for certain lawful permanent residents.
- In 1996, Congress enacted AEDPA, restricting § 212(c) relief for various convictions, and IIRIRA, which repealed § 212(c) and replaced it with a cancellation-of-removal scheme that excluded aggravated felons.
- The government initiated removal proceedings against St. Cyr on April 10, 1997, after AEDPA and IIRIRA took effect, and asserted that the new laws eliminated any authority to grant him § 212(c) relief.
- St. Cyr filed a 28 U.S.C. § 2241 habeas petition in federal district court, conceding deportability but claiming continued eligibility for § 212(c) relief because his guilty plea predated AEDPA and IIRIRA.
- The district court granted relief, and the Second Circuit affirmed.

## Issues

1. Whether AEDPA and IIRIRA stripped federal district courts of jurisdiction under 28 U.S.C. § 2241 to hear a lawful permanent resident’s habeas petition raising a pure question of law challenging removal.
2. Whether AEDPA and IIRIRA eliminated former § 212(c) discretionary relief for lawful permanent residents who pleaded guilty to deportable offenses before the 1996 enactments and were eligible for § 212(c) relief at the time of the plea.

## Decision

- The Supreme Court affirmed, holding (5–4, Stevens, J.) for St. Cyr on both issues.
- AEDPA and IIRIRA did not clearly repeal § 2241 habeas jurisdiction over pure questions of law in removal cases.
- Applying the repeal of § 212(c) relief to lawful permanent residents whose convictions resulted from pre-1996 plea agreements would have an impermissible retroactive effect where they would have been eligible for § 212(c) relief at the time of the plea.

## Legal Principles

- Statutes are presumed to permit judicial review of administrative action absent a clear statement to the contrary.
- Repeal of habeas jurisdiction requires a clear and unambiguous congressional statement; general limits on “judicial review” do not, without more, eliminate § 2241 habeas.
- When a plausible statutory construction would avoid serious constitutional questions, courts should adopt that construction; eliminating all habeas review of pure legal questions in this setting raises substantial Suspension Clause concerns.
- Under retroactivity analysis, a statute is disfavored if it attaches new legal consequences to completed events and disrupts reasonable reliance interests.
- The repeal of § 212(c) relief may not be applied to lawful permanent residents whose pre-1996 convictions were obtained by guilty plea, if they would have been eligible for § 212(c) relief under the law in effect when they pleaded guilty.

## Conclusion

The Court held that AEDPA and IIRIRA did not eliminate § 2241 habeas jurisdiction for legal challenges to removal and that former INA § 212(c) relief remained available to the defined class of lawful permanent residents who entered qualifying guilty pleas before the 1996 amendments and were eligible for discretionary relief at the time of the plea.


Immigr. & Naturalization Serv. v. St. Cyr, 533 U.S. 289 (2001)