Case Summary
**Case Summary: Judulang v. Gonzales, Docket No. 07-344**
**Court:** United States Supreme Court
**Argued:** November 7, 2011
**Decided:** January 25, 2012
**Citation:** 676 F.3d 564 (9th Cir. 2012)
**Overview:**
The case of Judulang v. Gonzales revolves around the eligibility for immigration relief under the Immigration and Nationality Act (INA), specifically regarding the issue of whether particular forms of relief are applicable to non-citizens who have been convicted of crimes.
**Facts:**
- The petitioner, Judulang, a native of Jamaica, had been a lawful permanent resident of the United States.
- He was convicted of a crime, which led to the initiation of deportation proceedings against him.
- Judulang sought relief from removal through an application for a waiver under § 212(c) of the INA, which had provided relief to certain lawful permanent residents facing deportation.
**Legal Issues:**
The case primarily considered whether the Board of Immigration Appeals (BIA) had the authority to apply a new rule that effectively barred Judulang from seeking relief under § 212(c) based on the nature of his conviction. The BIA had interpreted previous legislative changes to mean that certain criminal offenses disqualified individuals from pursuing relief under this provision.
**Decision:**
The Supreme Court ruled in favor of Judulang, emphasizing that the BIA's new rule was not consistent with the principles of due process and failed to provide a sufficient basis for denying relief. The Court underscored that § 212(c) should be applied uniformly and that the BIA's distinction in its interpretation was arbitrary in nature, with no appropriate justification.
**Implications:**
The ruling in Judulang v. Gonzales reinforced the idea that immigration relief provisions must be applied fairly and consistently, without arbitrary discrimination based on the nature of a conviction. This decision has had significant implications for non-citizens seeking relief from deportation, clarifying the standards under which such applications are evaluated.
**Conclusion:**
The Supreme Court's decision in Judulang v. Gonzales serves as a landmark case in immigration law, ensuring that due process is upheld in deportation proceedings and that the rights of lawful permanent residents are protected against arbitrary changes in BIA policies.