Garland v. Gonzalez
The Supreme Court ruled that a federal immigration law blocks district courts from issuing class-wide injunctions against immigration enforcement, undoing court orders that had required the government to hold bond hearings for thousands of detained immigrants.
The decision means detained immigrants seeking to challenge prolonged detention must now sue individually — a far heavier burden — rather than benefiting from a single lawsuit that covers everyone in the same situation.
How it got here: Two federal district courts certified classes and issued class-wide injunctions ordering bond hearings; the Ninth Circuit affirmed both; the Supreme Court agreed to hear the cases and directed the parties to address whether the district courts had jurisdiction to grant class-wide relief.
The Case in Depth
What happened
Two groups of immigrants from Mexico and El Salvador who had previously been ordered removed reentered the United States illegally, were detained under a federal immigration law while awaiting decisions on their claims that returning home would subject them to persecution or torture, and filed class-action lawsuits arguing that detainees are entitled to bond hearings after six months. Two federal district courts agreed and issued class-wide injunctions requiring the government to hold those hearings.
The question before the Court
Does a federal immigration law that limits court power over enforcement prevent district courts from issuing class-wide injunctions requiring the government to provide bond hearings to detained immigrants?
The Court's answer
No — federal district courts cannot issue class-wide injunctions ordering the government to provide bond hearings to detained immigrants. A provision of federal immigration law, §1252(f)(1), strips lower courts of authority to "enjoin or restrain the operation of" specified immigration enforcement statutes. The one narrow exception to that ban covers relief aimed at a single named immigrant in removal proceedings — not a certified class of thousands. The Court rejected the detainees' argument that the bar applies only to injunctions stopping lawful government action and not to orders compelling compliance with the law, finding that reading unnatural and inconsistent with the statute's structure.
The Court also read the exception's reference to "an individual alien" as singular and limited to a specific person — not an entire certified class. Because both district courts issued injunctions covering entire classes, those orders exceeded the courts' jurisdiction and are undone.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Thousands of immigrants detained under a federal removal statute can no longer rely on class-wide court orders to obtain bond hearings. Without the ability to sue as a group, each person must file a separate individual lawsuit — a nearly impossible task given that most immigration detainees lack legal representation, face language barriers, and are held far from courts and lawyers.
What changes now
The two cases are sent back to the Ninth Circuit with the class-wide injunctions reversed. Immigrants who were part of the certified classes will no longer receive bond hearings under those orders. Each individual must now seek relief in a separate proceeding. The Court left open whether §1252(f)(1) also bars class-wide declaratory relief, and did not decide whether the underlying statute actually requires bond hearings.
What this does not decide
The Court explicitly declined to decide whether §1252(f)(1) also bars class-wide declaratory relief (a court declaration without an enforcement order). It also left open whether the statute prevents injunctions that name multiple plaintiffs who are not a formally certified class. The merits of whether detained immigrants are entitled to bond hearings were not decided here.
Concurrences and dissents
Dissent in part — Justice Sotomayor
Justice Sotomayor agreed the government wins on the merits of the bond hearing question but sharply disagreed with the majority's §1252(f)(1) analysis. She argued that the statute's primary clause bars only injunctions that stop a statute from operating — not orders compelling the government to comply with it — and that the saving clause's 'individual alien' language, read in light of settled precedent on class actions, preserves district courts' authority to issue class-wide relief when every class member faces removal proceedings. She warned that the decision will leave vulnerable detainees without any practical way to enforce their rights.
How the Court got there
The legal reasoning, step by step
- The Court started with §1252(f)(1) of the Immigration and Nationality Act — a jurisdictional limit that strips lower courts of 'jurisdiction or authority' to 'enjoin or restrain the operation of' certain immigration enforcement statutes, covering the government's authority to inspect, detain, and remove immigrants.
- The terms 'enjoin' and 'restrain' carry their ordinary meanings: court orders directing someone to act or refrain from acting. 'Operation of' the covered statutes means the government's efforts to carry those laws out. Taken together, §1252(f)(1) generally bars lower courts from issuing any injunction telling federal immigration officials what to do — or not do — in enforcing the specified provisions.
- The Court rejected the detainees' argument that 'operation' means only lawful operation, such that injunctions compelling compliance with the statute wouldn't be covered. The Court found it perfectly ordinary to speak of a statute being operated unlawfully, and the provision's own prefatory language — 'regardless of the nature of the action or claim' — directly contradicts reading the bar as dependent on whether the government's underlying conduct was itself unlawful.
- Section 1252(f)(1) has one exception: lower courts may still issue injunctive relief 'with respect to the application of such provisions to an individual alien against whom proceedings . . . have been initiated.' The Court read the singular phrase 'an individual alien' to preserve relief only for a specific named person in removal proceedings — not for a certified class of many detainees, since class-wide relief is not limited to remedying unlawful application to any single individual.
- Because both district courts issued injunctions covering entire certified classes — not just the named plaintiffs — those injunctions fell entirely outside §1252(f)(1)'s narrow individual-alien exception and were therefore beyond the courts' jurisdiction to enter.
Doctrinal impact
Cases affected by this decision
Reaffirms Reno v. American-Arab Anti-Discrimination Comm. (525 U. S. 471)
The Court reaffirmed this prior statement that §1252(f)(1) bars class-wide injunctive relief in immigration cases.
Distinguishes Califano v. Yamasaki (442 U. S. 682)
The Court found this Social Security Act class-action ruling inapplicable because §1252(f)(1) limits rather than authorizes judicial review.