Patel v. Garland

Patel v. Garland centered on whether federal courts can review factual findings made by an immigration judge when denying an application for adjustment of status. Pankajkumar S. Patel, an Indian citizen, sought lawful permanent residence but was denied after an immigration judge found he lacked good moral character. This finding was based on Patel having falsely claimed U.S. citizenship on a Georgia driver’s license application. The Board of Immigration Appeals affirmed, and Patel petitioned for review in federal court. The government moved to dismiss, arguing that 8 U.S.C. § 1252(a)(2)(B)(i) strips courts of jurisdiction over any “judgment regarding the granting of relief” that is discretionary, including the factual underpinnings. On May 16, 2022, the U.S. Supreme Court, in a 5-4 decision authored by Justice Amy Coney Barrett, held that the jurisdictional bar extends to the factual determinations forming the basis of a discretionary denial. Justice Gorsuch dissented, contending the bar covers only the ultimate discretionary decision itself, not its underlying facts.

The U.S. Supreme Court held that the statute bars judicial review of factual findings underlying a discretionary denial of adjustment of status. The Court affirmed the Eleventh Circuit’s dismissal for lack of jurisdiction.

Whether 8 U.S.C. § 1252(a)(2)(B)(i) precludes federal courts from reviewing factual findings made by an immigration judge in the course of denying an application for discretionary relief, specifically adjustment of status.

The decision substantially restricts immigrants’ ability to challenge adverse factual findings in federal court when discretionary relief is denied. It consolidates unreviewable fact-finding authority within immigration agencies, leaving many errors uncorrected and reinforcing broad executive discretion in the immigration system.