Patel v. Garland

Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under 8 U. S. C. §1255 and the other provisions enumerated in 8 U. S. C. §1252(a)(2)(B)(i).

Petitioners, noncitizens that illegally entered the U.S., applied to the USCIS for an adjustment of status of citizenship but while the application was pending, Petitioner applied for a state driver’s license in which he indicated he was a U.S. citizen. With that knowledge, the USCIS denied the application based on misrepresentation. The immigration judge found Petitioner was not credible based on the facts and began removal proceedings. Petitioner appealed to the Court of Appeals, which held it lacked jurisdiction to hear Petitioner’s claims because all factual determinations made when considering a request for discretionary relief are prohibited by judicial review. The Court granted certiorari to decide whether courts are barred from judicial review of factual findings that underlie a decision denying discretionary relief from removal. The Court held that courts do lack jurisdiction to review facts in discretionary relief decisions, reasoning that, based on the text and context of § 1252(a)(2)(B)(i), the word “judgment” includes any authoritative decisions of discretionary relief from removal which includes factual findings and can be any judgment regarding and relating to granting relief. Therefore, courts lack jurisdiction and are prohibited from reviewing factual findings in the context of discretionary relief from removal. AFFIRMED.