McNary v. Haitian Refugee Center, Inc.

The Immigration Reform and Control Act of 1986 (Reform Act) established two amnesty programs for undocumented aliens. Immigration and Naturalization Services (INS) (defendant) administered the programs. One of the programs, the Special Agricultural Workers (SAW) program, granted temporary residence and, later, permanent residence for any alien farmworkers who could prove they had performed at least 90 days of qualifying agriculture work in the past year and were eligible for admission to the United States. Aliens filed an application under the SAW program with the Legalization Office of INS. The Legalization Office either denied or granted the application. The initial denial could be appealed to the legalization appeals unit for a final administrative decision. The Reform Act § 302, through its reference to the Immigration and Nationality Act (INA) § 210, prohibited “judicial review of a determination respecting an application for adjustment of status” except in limited circumstances related to deportation orders. The Haitian Refugee Center, Inc.; the Migration and Refugee Services of the Roman Catholic Diocese of Palm Beach; and 17 unsuccessful SAW applicants (plaintiffs) challenged INS procedures related to the SAW program in a district court. The district court found in favor of the SAW applicants. INS appealed, and the appellate court affirmed the district court ruling. INS then appealed to the United States Supreme Court.