Wednesday, November 13, 2013

Narenji v. Civiletti case brief

Narenji v. Civiletti case brief summary
617 F.2d 745 (1979)

Appellant United States Attorney General challenged a judgment of the United States District Court for the District of Columbia, which declared that an immigration regulation, 8 C.F.R. 214.5, violated equal protection. The Attorney General claimed that requiring appellee Iranian students to report to immigration officials was constitutional where the regulation's goal was to further resolution of Iranian hostage crisis and was rationally based.

The Iranian students challenged the constitutionality of an immigration regulation promulgated by the Attorney General. The regulation required all nonimmigrant alien postsecondary school students who are natives or citizens of Iran to report to immigration authorities to provide information regarding their residence and nonimmigrant status. Failure to comply with the regulation subjected individuals to deportation. The trial court declared the regulation unconstitutional where it drew distinctions among nonimmigrant students on the basis of nationality.


  • On appeal, the court held that the regulation was constitutional where immigration laws were not required to specifically authorize every action that the Attorney General took, so long as the action was reasonably related to the duties of the Attorney General. 
  • The court found that the regulation was reasonably related to the Attorney General's duties where the action was implemented as a fundamental element of the government's efforts to resolve the Iranian hostage crisis. 
  • No equal protection violation existed where distinctions were drawn on the basis of nationality with regard to immigrants as long as they were rationally based.
The court reversed the trial court's declaratory judgment with directions to dismiss the complaints and enter judgment for the Attorney General.

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