Bouarfa v. Mayorkas

604 U.S. 6
CourtSupreme Court of the United States
DecidedDecember 10, 2024
Docket23-583
StatusPublished

This text of 604 U.S. 6 (Bouarfa v. Mayorkas) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bouarfa v. Mayorkas, 604 U.S. 6 (2024).

Opinion

PRELIMINARY PRINT

Volume 604 U. S. Part 1 Pages 6–19

OFFICIAL REPORTS OF

THE SUPREME COURT December 10, 2024

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. 6 OCTOBER TERM, 2024

Syllabus

BOUARFA v. MAYORKAS, SECRETARY OF HOMELAND SECURITY, et al. certiorari to the united states court of appeals for the eleventh circuit No. 23–583. Argued October 15, 2024—Decided December 10, 2024 Amina Bouarfa, a U. S. citizen, began the process of obtaining permanent legal residence for Ala'a Hamayel, her noncitizen spouse, by fling a visa petition with the U. S. Citizenship and Immigration Services (USCIS). Relevant here, USCIS “shall . . . approve” a visa petition if it “deter- mines that the facts stated in the petition are true” and that the nonciti- zen is the petitioner's spouse. 8 U. S. C. § 1154(b) (emphasis added). But if the noncitizen has previously sought or received an immigration beneft “by reason of a marriage determined by the Attorney General to have been entered into for the purpose of evading the immigration laws”—known as the sham-marriage bar—the agency must deny the petition. § 1154(c). USCIS initially approved Bouarfa's visa petition. Two years later, the agency sent Bouarfa a Notice of Intent to Revoke its approval based on evidence suggesting that her husband had pre- viously entered into a marriage for the purpose of evading immigration laws. Although Bouarfa vigorously denied the evidence, the agency re- voked its prior approval based on the Secretary of Homeland Security's statutory authority under § 1155 to “revoke the approval of any petition” “for good and suffcient cause.” The Board of Immigration Appeals af- frmed the revocation, fnding that USCIS's determination that Hamayel had entered into a prior sham marriage that would have prevented ini- tial approval of the petition under § 1154(c) constituted “good and suff- cient cause” for revocation under § 1155. Bouarfa challenged the agency's revocation in federal court. The District Court dismissed the suit, holding that § 1252(a)(2)(B)(ii)—a pro- vision that strips federal courts of jurisdiction to review certain discre- tionary agency decisions—barred judicial review of the agency's revoca- tion. The Eleventh Circuit affrmed. Held: Revocation of an approved visa petition under § 1155 based on a sham-marriage determination by the Secretary is the kind of discretion- ary decision that falls within the purview of § 1252(a)(2)(B)(ii), which strips federal courts of jurisdiction to review certain actions “in the discretion of ” the agency. Pp. 13–19. (a) Section 1155 is a quintessential grant of discretion: The Secretary “may” revoke a previously approved visa petition “at any time” for what the Secretary deems “good and suffcient cause.” Such a broad grant Cite as: 604 U. S. 6 (2024) 7

of authority “fairly exudes deference” to the Secretary and is similar to other statutes held to “ `commi[t]' ” a decision “ `to agency discretion.' ” Webster v. Doe, 486 U. S. 592, 600. Congress did not impose specifc criteria or conditions limiting this authority, nor did it prescribe how or when the Secretary must act. Context reinforces the discretion- ary nature of § 1155. Section 1252(a)(2)(B)(ii)'s neighboring provision, § 1252(a)(2)(B)(i), bars judicial review under specifc provisions, each of which contains language indicating that the decisions involved are en- trusted to the discretion of the Attorney General. Section 1155 con- tains similar language. Pp. 13–15. (b) Bouarfa argues that although some revocations are discretionary, the revocation here was not, so § 1252(a)(2)(B)(ii) does not apply to pre- clude judicial review. Bouarfa contends that once the Secretary ap- proves a petition and later determines that the benefciary had pre- viously entered into a sham marriage, the Secretary has no choice but to revoke the agency's approval. Neither the statutory text nor its con- text limits the Secretary's discretion in this way. Pp. 15–19. (1) Contrary to Bouarfa's argument, § 1154(c)'s text nowhere cre- ates an ongoing duty for the agency to continually confrm that its initial approval was sound. Instead, § 1154(c)'s command to the agency ex- tends only to the point of approval. Turning to § 1154(c)'s context, Bou- arfa argues that because a noncitizen may use an approved visa petition to continue along the path toward permanent residency, Congress im- plicitly required the agency to continually reassess its prior approval. But nothing in the statutory scheme requires revisiting past decisions of approval; rather, each stage of the process comes with its own criteria. Indeed, the specifc grant of discretion in § 1155 to revoke prior approval of a visa petition forecloses the argument that Congress silently man- dated revocation in certain situations. Pp. 16–17. (2) Bouarfa's assertion that the Secretary always revokes the agency's approval of a visa petition if the agency later makes a sham- marriage determination makes no difference because Congress did not make the availability of judicial review dependent on agency practice. Rather, § 1252(a)(2)(B)(ii) bars judicial review of decisions “made discre- tionary by legislation.” Kucana v. Holder, 558 U. S. 233, 246–247 (em- phasis added). Nor is it unreasonable to suggest that Congress created a system in which a sham-marriage determination is subject to judicial review when an agency denies a visa petition but not when the agency revokes a prior approval. That distinction “refects Congress' choice to provide reduced procedural protection for discretionary relief.” Patel v. Garland, 596 U. S. 328, 345. Pp. 17–18. (3) Precedent, likewise, does not mandate Bouarfa's interpretation. Unlike the discretionary determination at issue in Patel v. Garland, § 1155's revocation authorization has no “threshold requirements” to ac- 8 BOUARFA v. MAYORKAS

Opinion of the Court

cess the relevant discretion, 596 U. S., at 332, 347, so Patel does not help Bouarfa. Finally, because the presumption that administrative action is subject to judicial review may be overcome by “ `clear and convincing evidence' of congressional intent to preclude judicial review,” Guerrero- Lasprilla v. Barr, 589 U. S. 221, 229, there is no need to resort to the presumption of reviewability where, as here, “the statute is clear,” Patel, 596 U. S., at 347. Pp. 18–19. 75 F. 4th 1157, affrmed.

Jackson, J., delivered the opinion for a unanimous Court.

Samir Deger-Sen argued the cause for petitioner. With him on the briefs were Peter Trombly, Margaret A. Upshaw, Peter E. Davis, and David Stoller. Colleen E. Roh Sinzdak argued the cause for respondents. With her on the brief were Solicitor General Prelogar, Prin- cipal Deputy Assistant Attorney General Boynton, Deputy Solicitor General Gannon, and Samuel P. Go.*

Page Justice Proof Pending Jackson delivered Publication the opinion of the Court. A common feature of our Nation's complex system of law- ful immigration is mandatory statutory rules paired with discretionary exceptions.

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Bouarfa v. Mayorkas
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604 U.S. 6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bouarfa-v-mayorkas-scotus-2024.