Azar v. Garza

In 2017, a 17-year-old undocumented immigrant detained in Texas obtained a state judicial bypass to access an abortion, but federal officials at the Office of Refugee Resettlement blocked her from leaving the shelter. Her court-appointed guardian and ACLU attorneys filed suit on her behalf, and a district court ordered the government to allow the procedure. The D.C. Circuit upheld the order. While the government sought an emergency stay from the Supreme Court, the minor obtained the abortion with assistance from her lawyers, who delayed informing the courts. On June 4, 2018, the Supreme Court vacated the appellate ruling and directed that the case be dismissed as moot, issuing a sharp rebuke of the attorneys for failing to disclose material developments.

The U.S. Supreme Court vacated the judgment of the D.C. Circuit and remanded the case with instructions to dismiss as moot. The Court strongly condemned the actions of the minor's legal team, with several justices suggesting possible disciplinary referrals, though no formal sanctions were imposed.

Whether the federal government could prevent an unaccompanied minor in immigration custody from exercising her constitutional right to an abortion, and whether the conduct of the plaintiff's attorneys in concealing the completed abortion from the courts amounted to sanctionable misconduct.

The case intensified the national debate over reproductive rights for immigrants, particularly minors in federal custody, and exposed tensions between immigration enforcement and constitutional liberties. It also prompted widespread discussion about legal ethics, the obligations of attorneys during emergency litigation, and the treatment of vulnerable populations within the detention system.