Facts
- Congress enacted the Immigration Reform and Control Act of 1986 (IRCA), which created the Special Agricultural Worker (SAW) program codified at 8 U.S.C. § 1160.
- SAW status allowed certain undocumented farmworkers to obtain lawful temporary resident status if they satisfied statutory requirements, including specified agricultural work and residence, and met admissibility criteria.
- IRCA added INA § 210(e), which limits judicial review of “a determination respecting an application” for SAW status, generally channeling review to petitions arising in connection with deportation orders.
- A nonprofit organization and a class of unsuccessful SAW applicants filed a federal class action alleging that the Immigration and Naturalization Service (INS) used unlawful, constitutionally deficient procedures in administering the SAW program in the Miami District.
- The suit targeted alleged systemic practices (e.g., defective interviewing and processing procedures) rather than seeking review of any particular applicant’s denial on the merits.
- The district court held it had federal-question jurisdiction over the collateral, program-wide challenge and found certain INS practices unlawful and unconstitutional.
- The Eleventh Circuit affirmed.
- The Supreme Court granted certiorari limited to whether INA § 210(e) precluded district-court jurisdiction over the pattern-or-practice procedural challenge.
Issues
- Whether INA § 210(e)’s bar on judicial review of “a determination respecting an application” for SAW status strips federal district courts of 28 U.S.C. § 1331 jurisdiction over class-wide challenges alleging a pattern or practice of unlawful and unconstitutional SAW application procedures.
Decision
- The Supreme Court affirmed the Eleventh Circuit.
- INA § 210(e) does not preclude federal district courts from exercising federal-question jurisdiction over general, collateral constitutional and statutory challenges to INS procedures used to process SAW applications.
- The jurisdictional bar applies to direct review of individual SAW status denials, not to systemic challenges to the legality of the process used in adjudication.
Legal Principles
- Courts presume judicial review of administrative action; preclusion requires clear and convincing evidence of congressional intent.
- Statutory language referring to review of “a determination” and “such a denial” is most naturally read to address direct review of individual adjudications, not broad challenges to agency-wide practices.
- When a statute channels review into a record-based appellate scheme tailored to individual cases, that structure may be inadequate for developing and resolving program-wide procedural and constitutional claims.
- District courts retain federal-question jurisdiction over collateral, pattern-or-practice claims alleging unconstitutional or unlawful agency procedures, even when Congress restricts review of individual determinations through a specialized scheme.
- A jurisdiction-stripping provision is not read to foreclose meaningful judicial review of constitutional and statutory challenges absent clear statutory direction.
Conclusion
The Court held that IRCA’s SAW judicial-review limits bar direct judicial review of individual SAW denials outside the deportation-review channel, but they do not eliminate district-court jurisdiction over class-wide challenges alleging unlawful and unconstitutional INS practices in administering the SAW application process.