Wilkinson v. Garland Revisions: 3/20/24

601 U.S. 209
CourtSupreme Court of the United States
DecidedMarch 19, 2024
Docket22-666
StatusPublished

This text of 601 U.S. 209 (Wilkinson v. Garland Revisions: 3/20/24) 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
Wilkinson v. Garland Revisions: 3/20/24, 601 U.S. 209 (2024).

Opinion

(Slip Opinion) OCTOBER TERM, 2023 1

Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

WILKINSON v. GARLAND, ATTORNEY GENERAL

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 22–666. Argued November 28, 2023—Decided March 19, 2024 Congress gives immigration judges discretionary power to cancel the re- moval of a noncitizen and instead permit the noncitizen to remain in the country lawfully. 8 U. S. C. §§1229b(a)–(b). An IJ faced with an application for cancellation of removal proceeds in two steps: The IJ must decide first whether the noncitizen is eligible for cancellation of removal under the statutory criteria. If the IJ finds the noncitizen statutorily eligible, the IJ must then decide whether to exercise discre- tion and grant relief. For determining eligibility, Congress has enu- merated four statutory criteria, one of which requires the noncitizen to “establis[h] that removal would result in exceptional and extremely unusual hardship to [the noncitizen’s] spouse, parent, or child,” who is a U. S. citizen or lawful permanent resident. §1229b(b)(1)(D). Petitioner Situ Kamu Wilkinson was arrested and detained by Im- migration and Customs Enforcement for remaining in the United States beyond the expiration of his tourist visa. Wilkinson applied for cancellation of removal based in part on hardship to his 7-year-old, U. S.-born son, M., who suffers from a serious medical condition and relies on Wilkinson for emotional and financial support. To meet the hardship standard, Wilkinson had to show that M. “would suffer hard- ship that is substantially different from or beyond that which would ordinarily be expected to result from [his] removal.” In re Monreal- Aguinaga, 23 I. & N. Dec. 56, 62. Considering all of the hardship fac- tors presented by Wilkinson in the aggregate, the IJ held that M.’s situation did not meet the statutory standard for “exceptional and ex- tremely unusual” hardship and denied Wilkinson’s application. The Board of Immigration Appeals affirmed. The Third Circuit held that it lacked the jurisdiction necessary to review the IJ’s discretionary hardship determination. This Court granted certiorari to determine 2 WILKINSON v. GARLAND

whether the IJ’s “exceptional and extremely unusual” hardship deter- mination is a mixed question of law and fact reviewable under §1252(a)(2)(D) or whether that determination is discretionary and therefore unreviewable under §1252(a)(2)(B)(i). Held: The Third Circuit erred in holding that it lacked jurisdiction to review the IJ’s determination in this case. Pp. 7–16. (a) The Third Circuit held that it lacked jurisdiction on the basis of §1252(a)(2)(B)(i), which makes unreviewable any “judgment[s] regard- ing the granting of [discretionary] relief” under §1229b’s cancellation of removal provision. Section 1252(a)(2)(D), however, restores juris- diction to review “questions of law.” The interaction between these two provisions is governed by two of this Court’s previous cases: Guerrero- Lasprilla v. Barr, 589 U. S. 221, and Patel v. Garland, 596 U. S. 328. In Guerrero-Lasprilla, the Fifth Circuit reasoned that whether a noncitizen acted diligently in attempting to reopen removal proceed- ings for purposes of equitable tolling was a question of fact, not a ju- risdiction-restoring “questio[n] of law”. This Court reversed, holding that “questions of law” in §1252(a)(2)(D) included mixed questions of law and fact. 589 U. S., at 225. The Court rejected the Government’s argument that “questions of law” referred only to mixed questions that are primarily legal rather than primarily factual. Then, in Patel, this Court affirmed an Eleventh Circuit holding that it lacked jurisdiction to review an IJ’s factual credibility determinations that fell within §1252(a)(2)(B)(i)’s jurisdictional bar. In so doing, the Court held that §1252(a)(2)(D) did not restore jurisdiction in the case because “ques- tions of fact” are indisputably not “questions of law.” Pp. 7–11. (b) Wilkinson argues that §1252(a)(2)(D) restores jurisdiction in this case because the threshold question whether a noncitizen is statutorily eligible for cancellation of removal requires a court to assess whether an IJ correctly applied the statutory standard to a given set of facts. Guerrero-Lasprilla compels the conclusion that the application of the statutory “exceptional and extremely unusual hardship” standard to a given set of facts presents a mixed question of law and fact. A mixed question may require “primarily legal or factual work,” and just be- cause it may require a court to immerse itself in facts does not trans- form the question into one of fact. U. S. Bank N. A. v. Village at Lak- eridge, LLC, 583 U. S. 387, 396. In this case, the application of the hardship standard—which re- quires an IJ to evaluate a number of factors in determining whether any hardship to a U. S. citizen or permanent-resident family member is substantially different from what would normally be expected in the removal of a close family member—concededly requires a close exami- nation of the facts. As in Guerrero-Lasprilla, a mixed question that requires close engagement with the facts is still a mixed question, and Cite as: 601 U. S. ____ (2024) 3

therefore a “questio[n] of law” reviewable under §1252(a)(2)(D). And as in Patel, the IJ’s underlying factual determinations that Wilkinson was credible or that M. had a serious medical condition would be un- reviewable factual questions under §1252(a)(2)(D). Pp. 11–12. (c) The Government’s counterarguments are unpersuasive. First, nothing in Guerrero-Lasprilla or this Court’s other precedents limits that case solely to judicially created standards like the “due diligence” standard for equitable tolling. And this Court has frequently observed that the application of a “statutory standard” presents a mixed ques- tion of law and fact. See, e.g., Pullman-Standard v. Swint, 456 U. S. 273, 289, n. 19. Second, the case of Williamsport Wire Rope Co. v. United States, 277 U. S. 551, on which the Government relies, has no relevance to the question presented here on §1252(a)(2)(D), and the Government provides no basis for porting the interpretation of “excep- tional hardship” in that case to this one. Nor is the Government’s ar- gument from the statutory history of the “hardship requirement” any more persuasive. Finally, the argument that a primarily factual mixed question is a question of fact was previously rejected in Guerrero- Lasprilla, and nothing in §1252(a)(2)(D) supports the Government’s view that the phrase “questions of law” is so limited. Pp. 12–15. Reversed in part, vacated in part and remanded.

SOTOMAYOR, J., delivered the opinion of the Court, in which KAGAN, GORSUCH, KAVANAUGH, and BARRETT, JJ., joined. JACKSON, J., filed an opinion concurring in the judgment. ROBERTS, C. J., filed a dissenting opinion.

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601 U.S. 209, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilkinson-v-garland-revisions-32024-scotus-2024.