INS v. St. Cyr

Defendant, a United States permit resident from Haiti, pled guilty in state court to a charge of selling a controlled substance in violation of state law. The Defendant’s conviction made him deportable. At the time of the Defendant’s conviction, under the applicable federal law, he was eligible to receive a waiver for deportation at the Attorney General’s discretion. However, once the Defendant’s removal proceedings commenced, the Antiterrorism and Effective Death Penalty Act (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) had gone into effect, which took away the Attorney General’s discretion to grant a waiver for deportation. The Defendant filed a habeas corpus petition, arguing that the discretionary relief from the abrogated statutes should still apply to him because he pled guilty to a deportable crime before the AEDPA and IIRIRA were enacted. The Supreme Court agreed with the Defendant, holding that the discretionary relief remained available to aliens whose convictions were obtained through plea agreements and who had been eligible for relief under the law in effect at the time of their conduct and plea.

“Elementary considerations of fairness dictate that individuals should have an opportunity to know what the law is and to conform their conduct accordingly; settled expectations should not be lightly disrupted. For that reason, the ‘principle that the legal effect of conduct should ordinarily be assessed under the law that existed when the conduct took place has timeless and universal human appeal.'” p.316