INS v. Lopez-Mendoza case brief

INS v. Lopez-Mendoza case brief summary
468 U.S. 1032 (1984)

CASE SYNOPSIS

Petitioner, Immigration and Naturalization Service (INS), challenged the judgment of the United States Court of Appeals for the Ninth Circuit, which held that the exclusionary rule of the 4th Amendment applied to the INS deportation hearings.

CASE FACTS
-Respondent illegal aliens were arrested by petitioner INS.
-At their deportation hearings, respondents attempted to suppress evidence of their status, arguing that under the exclusionary rule of the 4th Amendment, petitioner's illegal arrest of respondents had to be suppressed.
-Petitioner opposed respondents' motion, claiming that the criminal exclusionary rule did not apply to civil proceedings such as a deportation hearing.
-The court of appeals reversed one deportation order and remanded the other.

DISCUSSION

• On appeal, the Court reversed the court of appeals, holding that the exclusionary rule did not apply to civil proceedings such as petitioner's deportation hearing, since the purpose of the exclusionary rule was to deter police misconduct, and that did not exist in this situation. 
• Application of the exclusionary rule to civil deportation proceedings could be justified only if the rule was likely to add significant protection to U.S. Constitution 4th Amendment  rights. 
• The Court concluded by stating that excluding respondents' illegal status would have allowed them to continue breaking the law, something that the exclusionary rule was never designed to do.

OUTCOME

The Court reversed the decision of the lower court and held that the Fourth Amendment's exclusionary rule did not apply to the INS' deportation hearings, and thus, respondents were properly determined to be aliens subject to deportation.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)