Clark v. Martinez, 543 U.S. 371 (2005)
Primary Holding
The Supreme Court held that the Secretary of Homeland Security does not have the authority to continue detaining an inadmissible alien beyond the 90-day removal period mandated by 8 U.S.C. § 1231(a)(1)(A) unless the alien is subject to a specific exception under the law.
In the case of Clark v. Martinez, the Supreme Court decided that the government cannot keep someone in detention for more than 90 days if they are ordered to be removed from the U.S., unless there are specific legal reasons to do so. This ruling is important because it protects the rights of individuals facing deportation, ensuring they cannot be held indefinitely without proper justification. This case is relevant for anyone who might be in a similar situation, as it sets a clear limit on how long the government can detain someone who is not allowed to stay in the country.
AI-generated plain-language summary to help you understand this case
In Clark v. Martinez, the underlying events center around two Cuban nationals, Sergio Suarez Martinez and Daniel Benitez, who arrived in the United States during the Mariel boatlift in June 1980 and were paroled into the country. Both individuals sought to adjust their immigration status to that of lawful permanent residents under the Cuban Refugee Adjustment Act. However, they were rendered inadmissible due to prior criminal convictions. Martinez had convictions for assault with a deadly weapon and burglary, while Benitez had a history of grand theft and multiple armed offenses. Their applications for adjustment of status were denied, and they continued to accrue additional criminal convictions after their applications were rejected. Procedurally, the case reached the Supreme Court through writs of certiorari from the United States Court of Appeals for the Ninth Circuit and the Eleventh Circuit. The central issue was the authority of the Secretary of Homeland Security to detain inadmissible aliens beyond the 90-day period mandated for removal after a removal order has been issued. The case involved the interpretation of immigration statutes regarding the detention of individuals who had been ordered removed but could not be deported within the specified timeframe. The relevant background context highlights the legal framework governing the detention and removal of aliens in the United States. Under 8 U.S.C. §1231(a)(1)(A), the Secretary is required to remove an alien within 90 days after a removal order, but the law also allows for discretionary detention. The case raised significant questions about the limits of this authority and the rights of individuals who, despite being inadmissible, were unable to be removed from the country within the statutory period.
Whether the Secretary of Homeland Security has the authority to continue to detain an inadmissible alien subject to a removal order after the 90-day removal period has elapsed.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 13, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Jama v. Immigration and Customs Enforcement, 543 U.S. 335 (2005)
Consumer LostThe provision of 8 U.S.C. §1231(b)(2) does not require the advance consent of the destination country for the removal of an alien; therefore, an alien can be removed to a country even if that country has no functioning government to provide such consent.
Gonzalez v. Crosby, 545 U.S. 524 (2005)
Consumer LostA motion for relief from a judgment in a habeas corpus case, filed under Federal Rule of Civil Procedure 60(b), is subject to the restrictions that apply to “second or successive” habeas corpus petitions under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).
Medellín v. Dretke, 544 U.S. 660 (2005)
Consumer LostA federal court is not bound by the International Court of Justice's ruling regarding the reconsideration of claims under the Vienna Convention on Consular Relations, and procedural default doctrines may apply to such claims in U.S. courts.
Johnson v. United States, 544 U.S. 295 (2005)
Consumer LostThe period for the 1-year statute of limitations under 28 U.S.C. §2255 begins when a petitioner receives notice of the order vacating a prior conviction used to enhance their federal sentence, provided that the petitioner has pursued the vacatur with due diligence in state court.