Garland v. Gonzalez

Garland v. Gonzalez, decided on June 13, 2022, addressed whether noncitizens detained under 8 U.S.C. § 1226(a) during removal proceedings are entitled to bond hearings. Esteban Aleman Gonzalez and Jose Eduardo Gonzalez, held in California without individualized hearings, filed a class-action lawsuit against the federal government. The Ninth Circuit ruled that detained immigrants must receive bond hearings after six months. The Supreme Court, in a 6-3 decision written by Justice Alito, reversed, holding that the Immigration and Nationality Act’s plain text imposes no such requirement. The Court found that the authority to grant bond rests with the Department of Homeland Security and that the lower court lacked jurisdiction to issue class-wide injunctive relief under 8 U.S.C. § 1252(f)(1).

The Supreme Court reversed the Ninth Circuit in a 6-3 decision, ruling that 8 U.S.C. § 1226(a) does not require bond hearings and that 8 U.S.C. § 1252(f)(1) prohibits class-wide injunctions against the operation of the detention statutes.

Whether noncitizens detained under 8 U.S.C. § 1226(a) have a statutory right to a bond hearing before an immigration judge, and whether federal courts have jurisdiction to grant class-wide injunctive relief ordering such hearings.

The ruling significantly curtailed the ability of thousands of detained immigrants to obtain release while their cases proceed, allowing indefinite detention without periodic individualized review. Immigrant rights groups condemned the decision as a blow to due process, while the administration emphasized adherence to statutory text. It intensified legislative advocacy for immigration detention reform.