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Patel v. Garland

Docket: 20-979 Decision Date: 2022-05-16
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This links to the official slip opinion PDF.
How to read this page

Below are plain-language sections to help you understand what the Court decided in Patel v. Garland 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 Patel v. Garland.

In Patel v. Garland, the Supreme Court addressed whether federal courts have jurisdiction to review factual determinations in discretionary-relief proceedings under immigration law. The Court found that such reviews are precluded by § 1252(a)(2)(B)(i), which bars judicial review of any judgment regarding the granting of relief. This decision resolves a circuit conflict concerning the scope of judicial review in these contexts.

Holding

The single most important “bottom line” of what the Court decided in Patel v. Garland.

The Court held that federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under § 1255 and related provisions.

Constitutional Concepts

These are the Constitution-related themes that appear in Patel v. Garland. Click a concept to see other cases that involve the same idea.

  • Why Judicial Review is relevant to Patel v. Garland

    The case primarily deals with the scope of judicial review over factual determinations in discretionary-relief proceedings.

    Syllabus excerpt (verbatim)
    Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under § 1255 and the other provisions enumerated in § 1252(a)(2)(B)(i).
  • Why Procedural Due Process is relevant to Patel v. Garland

    The case involves the procedural aspect of whether factual determinations in immigration proceedings are subject to judicial review, which relates to procedural due process.

    Syllabus excerpt (verbatim)
    The distinction simply reflects Congress' choice to provide reduced procedural protection for discretionary relief.

Key Quotes

Short excerpts from the syllabus in Patel v. Garland that support the summary and concepts above.

  • "Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under § 1255."
  • "The text and context of § 1252(a)(2)(B)(i) clearly indicate that judicial review of fact determinations is precluded in the discretionary-relief context."
  • "The word 'any' has an expansive meaning."

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