Campos-Chaves v. Garland

The U.S. Supreme Court in Campos-Chaves v. Garland consolidated two immigration cases involving Moris Esmelis Campos-Chaves, a Salvadoran national, and Varinder Singh, an Indian national. Both received initial notices to appear lacking the specific date and time of their removal hearings, but later received supplemental notices containing that information. Neither appeared, and immigration judges ordered them removed in absentia. They challenged those orders, arguing the initial notices were statutorily deficient. In a 5-4 decision authored by Justice Samuel Alito, the Court held that the government satisfied the notice requirements under 8 U.S.C. § 1229(a) when it sent a subsequent notice with the missing hearing details. The majority reasoned that the statute does not require all information in a single document. The ruling resolved a circuit split, with the Fifth and Ninth Circuits reaching opposite conclusions.

The Supreme Court ruled 5-4 in favor of the government, holding that a defective initial notice can be cured by a subsequent notice providing the hearing time and place. The in absentia removal orders were upheld.

Whether an initial notice to appear that omits the time and place of a removal hearing satisfies the statutory notice requirements under 8 U.S.C. § 1229(a) when a later supplemental notice provides the missing details, thereby permitting an in absentia removal order.

The decision strengthens the government's ability to conduct removal proceedings when initial notices are incomplete, potentially increasing in absentia deportation orders. Immigrant rights advocates criticized the ruling for weakening due process protections, while the government viewed it as resolving procedural ambiguity and reducing litigation delays in immigration courts.