Johnson v. Arteaga-Martinez
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Johnson v. Arteaga-Martinez 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 Johnson v. Arteaga-Martinez.
In Johnson v. Arteaga-Martinez, the Supreme Court addressed whether noncitizens detained under 8 U.S.C. § 1231(a)(6) are entitled to bond hearings after six months of detention. The Court found that the statute does not require such hearings with specific procedures as mandated by the Third Circuit. The case was reversed and remanded for further consideration of constitutional challenges.
Holding
The single most important “bottom line” of what the Court decided in Johnson v. Arteaga-Martinez.
The Court held that Section 1231(a)(6) does not require the government to provide bond hearings for noncitizens detained for six months.
Constitutional Concepts
These are the Constitution-related themes that appear in Johnson v. Arteaga-Martinez. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Johnson v. Arteaga-Martinez
The case involves the procedural due process rights of noncitizens regarding detention and the requirement of bond hearings.
Syllabus excerpt (verbatim)Arteaga-Martinez fled a petition for a writ of habeas corpus in District Court challenging, on both statutory and constitutional grounds, his continued detention without a bond hearing.
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Why Judicial Review is relevant to Johnson v. Arteaga-Martinez
The Court reviewed the statutory interpretation of § 1231(a)(6) and its application, which involves judicial review of government action.
Syllabus excerpt (verbatim)Faithfully applying precedent, the Court cannot discern the bond hearing procedures required below from § 1231(a)(6)'s text.
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Why Substantive Due Process is relevant to Johnson v. Arteaga-Martinez
The case touches on the substantive due process issue of indefinite detention without a bond hearing.
Syllabus excerpt (verbatim)Zadvydas v. Davis, 533 U. S. 678, which identifed ambiguity in § 1231(a)(6)'s permissive language, supports a view that § 1231(a)(6) implicitly incorporates the specifc bond hearing requirements and procedures imposed by the Court of Appeals.
Key Quotes
Short excerpts from the syllabus in Johnson v. Arteaga-Martinez that support the summary and concepts above.
Section 1231(a)(6) does not require the Government to provide noncitizens detained for six months with bond hearings.
There is no plausible construction of the text of § 1231(a)(6) that requires the Government to provide bond hearings.
Zadvydas does not require, and Jennings v. Rodriguez does not permit, the Third Circuit's application of the canon of constitutional avoidance.