## Facts

- Congress enacted the Immigration Reform and Control Act of 1986 (IRCA), which created a legalization program requiring eligible undocumented aliens to apply first for temporary resident status by showing continuous unlawful residence and continuous physical presence for specified periods.
- The Immigration and Naturalization Service (INS) issued regulations interpreting aspects of IRCA’s “continuous physical presence” and “continuous unlawful residence” requirements.
- Two separate class actions challenged different INS regulations, alleging the rules improperly narrowed eligibility for legalization.
- The district courts invalidated the challenged regulations and granted relief, including orders directing the INS to accept applications beyond the statutory deadline.
- The Ninth Circuit consolidated the appeals, rejected the government’s argument that IRCA’s judicial review provisions barred district court jurisdiction, and affirmed.
- The Supreme Court granted review to decide whether IRCA’s exclusive review scheme barred district court jurisdiction and whether the challenges were ripe.

## Issues

1. Whether IRCA’s exclusive review provisions channeling review of “a denial” of adjustment of status to petitions for review of deportation orders strip district courts of jurisdiction over classwide challenges to the legality of INS regulations.
2. Whether the class claims were ripe when many class members had not filed legalization applications or received individual denials under the challenged regulations.

## Decision

- The Court vacated the Ninth Circuit’s judgment and remanded for further proceedings.
- The Court held that IRCA’s exclusive review scheme does not categorically preclude district court jurisdiction over an action challenging the legality of an INS regulation that does not depend on the denial of any individual application.
- The Court held that many class members’ claims were not ripe because promulgation of the regulations did not, by itself, affect them concretely enough to create a justiciable case or controversy.
- The Court concluded the record was insufficient to determine which class members (if any) had ripe claims, requiring remand.

## Legal Principles

- A statutory provision channeling judicial review of “a denial” of a benefit application does not necessarily bar district court jurisdiction over facial or systemic challenges to the legality of governing regulations when the suit does not rely on any individual denial.
- Article III ripeness requires a concrete present injury (or sufficiently imminent hardship) and issues fit for judicial decision; the mere existence of a regulation affecting access to a benefit may be insufficient without an actual denial or an effectively unavoidable barrier to applying.
- In class actions challenging benefit-eligibility regulations, courts may need an individualized record to determine which class members have experienced a concrete application of the rule sufficient to support jurisdiction.

## Conclusion

The Court held that IRCA’s review-channeling provisions did not automatically foreclose district court suits attacking INS legalization regulations, but it vacated and remanded because many class members had not shown a concrete, ripe injury tied to the regulations’ application to them.


Reno v. Catholic Soc. Servs., Inc., 509 U.S. 43 (1993)