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Facts of the Case

The IRCA established the SAW program to grant lawful status to undocumented agricultural workers who met specific residency and employment criteria. Applicants were required to submit evidence and attend interviews with INS officials. Under §210(e)(1) of the Immigration and Nationality Act (INA), judicial review of individual denials was allowed only in the context of deportation proceedings, which were subject to limited review by courts of appeals.

The Haitian Refugee Center and several individual SAW applicants filed a class-action lawsuit, alleging that the INS employed arbitrary and unconstitutional practices in processing SAW applications. These included a lack of competent interpreters, inadequate opportunities for applicants to present evidence or challenge adverse findings, and failure to maintain proper records of interviews. The plaintiffs argued that these procedural deficiencies violated the Fifth Amendment’s due process clause and the statutory requirements of the IRCA.

The District Court found that the INS’s practices violated both constitutional and statutory standards. It issued an injunction requiring changes to the SAW application process, including the use of interpreters, opportunities to present witnesses, and improved recordkeeping. The Eleventh Circuit Court of Appeals affirmed this decision.

Court’s Analysis

The Supreme Court’s analysis focused on the scope of §210(e)(1) and whether it precluded judicial review of systemic procedural challenges. The Court determined that the language of §210(e)(1), which barred review of “a determination respecting an application,” applied only to individual SAW application denials, not to broader challenges to the INS’s overall procedures.

The Court emphasized the importance of judicial oversight to ensure constitutional compliance in administrative processes. It noted that the statutory scheme did not provide an adequate mechanism for addressing systemic violations. Requiring applicants to pursue individual judicial review within deportation proceedings was impractical, as it would often necessitate applicants surrendering themselves for deportation to access the courts. Moreover, the record generated in such proceedings would likely be insufficient to address claims of widespread procedural deficiencies.

The Court’s decision was guided by the principle that statutes should be interpreted to allow judicial review of constitutional claims unless Congress explicitly states otherwise. Here, the absence of clear congressional language mandating the exclusion of such review led the Court to conclude that district courts retained jurisdiction over collateral challenges to INS procedures.