News & Insights

Facts:

• Mezei, a lawful resident alien, lived in the U.S. for 25 years before traveling abroad to visit his ill mother in Hungary.
• He was unable to re-enter the U.S. upon his return in 1950, as the Attorney General excluded him based on confidential national security concerns.
• Mezei remained detained on Ellis Island because no other country would accept him, leading to indefinite detention.

Legal Issues:

• Does indefinite detention of an excluded alien on U.S. territory violate the constitutional guarantee of due process?
• Can courts compel the government to disclose confidential evidence used to exclude an alien?

Supreme Court’s Analysis:

• National Sovereignty and Admission Rights:
  • The Court emphasized that the power to admit or exclude aliens lies exclusively with Congress and the executive branch.
  • Aliens seeking initial entry have no constitutional right to procedural due process, even if physically present on U.S. soil (Ellis Island in this case).
• Due Process for Exclusion:
  • The Court distinguished between aliens already admitted and those seeking entry, holding that exclusion procedures authorized by Congress, even without a hearing, satisfy due process for aliens denied entry.
• Judicial Review of National Security Decisions:
  • The Court deferred to the Attorney General’s authority to exclude Mezei based on confidential information, citing the need to protect public interest and national security.

Outcome:

• The Supreme Court reversed lower court rulings that had granted Mezei conditional parole into the U.S.
• It upheld the Attorney General’s authority to exclude and detain Mezei indefinitely on national security grounds without a hearing or disclosure of evidence.