Reno v. Flores
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| Reno v. Flores | |
|---|---|
| Case name | Reno v. Flores |
| Citations | 507 U.S. 292 (1993) |
| Decided | March 23, 1993 |
| Court | Supreme Court of the United States |
| Majority | Scalia |
| Joinmajority | Rehnquist, White, O'Connor, Kennedy |
| Concurrence | Souter (in judgment) |
| Dissent | Blackmun |
| Laws applied | Fifth Amendment |
Reno v. Flores Reno v. Flores was a 1993 Supreme Court decision addressing the detention and release of unaccompanied noncitizen minors, the authority of the Immigration and Naturalization Service, and the application of procedural due process under the Fifth Amendment. The case arose from litigation involving immigrant rights advocates, state juvenile authorities, and federal agencies following the detention of a Mexican national minor at a Los Angeles immigration facility.
Background
The litigation began after the arrest of a sixteen-year-old Mexican national, who was detained by the Immigration and Naturalization Service at an Immigration and Naturalization Service facility in Los Angeles, California and held in the Los Angeles Juvenile Hall. The minor's case prompted involvement from the American Civil Liberties Union, the Mexican American Legal Defense and Educational Fund, and local Los Angeles County child welfare authorities. The dispute implicated statutes and regulations administered by the Immigration and Nationality Act, the Department of Justice, and the Office of Refugee Resettlement regarding the custody, release, and treatment of noncitizen minors.
Case Details and Procedural History
Plaintiffs challenged INS policies that permitted prolonged detention of unaccompanied minors and routine release only to certain designated adults or agencies, filing suit in the United States District Court for the Central District of California. The district court issued a class-action injunction and approved a consent decree, known as the Flores Agreement, which involved parties including the Los Angeles County Department of Children and Family Services, federal defendants from the Immigration and Naturalization Service, and advocacy organizations such as the American Civil Liberties Union. The United States Court of Appeals for the Ninth Circuit reviewed the decree after the INS appealed, prompting further litigation that culminated in review by the Supreme Court of the United States.
Supreme Court Decision
In a plurality opinion authored by Antonin Scalia, the Court reversed parts of the Ninth Circuit's judgment, holding that the INS regulations and statutory scheme did not create a protected liberty interest requiring the procedures plaintiffs sought under the Fifth Amendment. The opinion was joined by Chief Justice William Rehnquist, Justice Harry Blackmun did not join the majority and wrote a dissenting opinion criticizing the plurality's approach to liberty interests and procedural protections; Justice David Souter concurred only in the judgment. The decision narrowed the scope of judicially enforceable rights derived from administrative regulations promulgated under the Immigration and Nationality Act.
Legal Reasoning and Precedent
The plurality applied precedents concerning protected liberty interests, including analysis from Board of Regents of State Colleges v. Roth and Wolff v. McDonnell, to determine whether INS regulations created an entitlement to release or to certain procedures. The Court emphasized the statutory discretion conferred by the Immigration and Nationality Act and referenced prior administrative law decisions such as Chicago & Southern Air Lines v. Waterman and Mathews v. Eldridge for procedural-due-process balancing. The ruling interpreted the scope of regulatory-based entitlements similarly to earlier decisions involving federal regulatory schemes and administrative discretion, engaging with doctrines developed in cases like Goldberg v. Kelly and Perry v. Sindermann while distinguishing the facts at issue.
Impact and Aftermath
The decision affected nationwide practices concerning the detention and release of unaccompanied noncitizen minors, influencing policy at the Immigration and Naturalization Service and later agencies succeeding the INS, including the Department of Homeland Security and U.S. Immigration and Customs Enforcement. The Flores Agreement, which originated in the district court proceedings, continued to shape litigation and enforcement, prompting advocacy by organizations such as the American Civil Liberties Union and National Immigration Law Center. State and local actors, including the Los Angeles County Board of Supervisors and California Department of Social Services, engaged in policy responses to comply with or challenge the practical consequences of the ruling.
Subsequent Litigation and Policy Changes
Later challenges and negotiations revisited the Flores Agreement and its implementation, involving federal actors such as the Executive Office for Immigration Review, the Office of Refugee Resettlement, and administrations of Presidents Bill Clinton, George W. Bush, Barack Obama, and Donald Trump. The matter resurfaced in federal courts and administrative rulemaking concerning detention standards, family separation policies, and the treatment of minors at the border, intersecting with cases like Zadvydas v. Davis and regulatory actions under the Department of Homeland Security. Ongoing litigation and settlement discussions continued to involve the United States District Court for the Central District of California and advocacy groups including the Kids in Need of Defense and the National Immigrant Justice Center.