INS v. St. Cyr, 533 U.S. 289 (U.S. 2001)
INS v. St.
1) Did AEDPA and IIRIRA repeal federal district courts' habeas corpus jurisdiction under 28 U.S.C. § 2241 to review pure questions of law in removal proceedings involving criminal aliens? 2) Does Congress's repeal of former INA § 212(c) apply retroactively to bar discretionary relief for lawful permanent residents who pleaded guilty to deportable offenses before AEDPA/IIRIRA?
• Presumption against retroactivity: Absent a clear statement, courts will not construe statutes to attach new legal consequences to events completed before enactment (Landgraf v. USI Film Products). Eliminating eligibility for discretionary relief may constitute an impermissible retroactive effect when individuals reasonably relied on prior law in entering guilty pleas. • Habeas clear-statement rule and constitutional avoidance: Traditional habeas jurisdiction under 28 U.S.C. § 2241 is not repealed by implication; Congress must clearly and unambiguously indicate its intent to withdraw habeas review. Ambiguities are resolved to avoid serious constitutional questions under the Suspension Clause (U.S. Const. art. I, § 9, cl. 2). • Former INA § 212(c): Prior to its 1996 repeal, § 212(c) allowed certain lawful permanent residents with at least seven years' lawful domicile to apply for discretionary relief from deportation, subject to statutory bars.
1) No. Neither AEDPA nor IIRIRA expressly repealed 28 U.S.C. § 2241 habeas jurisdiction over pure questions of law in removal cases; district courts retain that jurisdiction. 2) No. The repeal of INA § 212(c) does not apply retroactively to noncitizens who pleaded guilty before AEDPA/IIRIRA; those individuals remain eligible to apply for § 212(c) relief.
St. Cyr is foundational for three reasons: (1) It cements the presumption against retroactivity in the immigration context, showing how reliance interests in plea bargaining can preserve eligibility for discretionary relief; (2) it safeguards habeas corpus review for pure legal questions absent a clear congressional repeal, anchoring the role of constitutional avoidance and the Suspension Clause in immigration adjudication; and (3) it illustrates how courts parse complex, overlapping jurisdiction-stripping and transitional provisions in major reform statutes. For law students, the case is a prime vehicle to master Landgraf, clear-statement rules, and the interplay between criminal pleas and immigration consequences.