Massieu v. Reno

After four unsuccessful attempts by the United States government to extradite Mario Ruiz Massieu (plaintiff) pursuant to Mexico’s extradition request, Massieu was arrested by the Immigration and Naturalization Service (INS) and ordered to show cause as to why he should remain in the United States and not be deported to Mexico. Massieu had entered the United States legally, and there was no evidence that he committed any act justifying extradition or deportation. The secretary of state provided only that Massieu remaining in the United States would create adverse foreign-policy consequences due to allegations asserted by Mexico and requested that Massieu be deported. Massieu filed a request for a permanent injunction to enjoin his deportation, arguing that the deportation statute, which gave the secretary of state absolute discretion to deport legal aliens, was unconstitutional. Massieu asserted that deportation violated his First Amendment right to criticize Mexico’s political system, was an attempt to circumvent four failed extradition attempts, and was based on an unconstitutional statute that was void for vagueness, violating his due-process rights. The United States Department of Justice (defendant) argued in favor of the statute’s constitutionality and claimed that the court lacked jurisdiction to hear the case because it was a political question involving foreign policy, because Massieu had not exhausted all INS remedies, and because the doctrine of constitutional avoidance prevented the court from resolving the case.