Reno v. Catholic Social Services, Inc.

In 1986, Congress enacted the Immigration Reform and Control Act of 1986 (Act), which created an amnesty program that permitted unlawfully present foreign nationals to legalize their immigration status if they applied before a statutory deadline. The Act included exclusive-review provisions that barred judicial review of agency denials of amnesty applications. The Immigration and Naturalization Service (INS) (defendant) implemented regulations interpreting certain statutory requirements in ways that restricted the number of applicants who could qualify for the amnesty program. The INS also prepared a legalization manual for its employees to use in reviewing amnesty applications. The manual instructed INS employees to conduct a pre-filing review with applicants and to reject applications that did not satisfy the statutory requirements. This type of rejection was called front desking. Catholic Social Services, Inc. and others (plaintiffs) filed two class-action suits against the INS and various government officials (defendants), challenging the validity of the new regulations. The evidence reflected that some amnesty applications had been front desked as a result of applying the new regulations. The district courts ruled in favor of the plaintiffs. The two class-action suits were consolidated on appeal, and the court of appeals affirmed. The United States Supreme Court granted certiorari on the issue of jurisdiction.