1. Introduction

Barton v. Barr (140 S. Ct. 1442, 2020) is a landmark decision by the United States Supreme Court that clarifies the eligibility criteria for cancellation of removal for lawful permanent residents (LPRs) who have committed certain serious crimes. The case centers around Andre Martello Barton, a Jamaican national and LPR, who faced removal proceedings based on multiple criminal convictions, including firearms and drug offenses.

2. Summary of the Judgment

The Supreme Court, in a majority opinion delivered by Justice Kavanaugh, held that for the purposes of cancellation of removal, a §1182(a)(2) offense committed during the initial seven years of residence does not need to be one of the offenses of removal. This decision affirmed the lower courts' rulings that Barton was not eligible for cancellation of removal due to his prior aggravated assault offenses committed within his first seven years as an LPR.

3. Analysis

3.1 Precedents Cited

The Court referenced several precedents to support its interpretation:

• In re Jurado-Delgado (BIA 2006): Affirmed that prior §1182(a)(2) offenses can preclude cancellation of removal even if they are not the cause of removal.
• In re Perez (BIA 1999): Established that the date of commission of the offense, not the date of conviction, governs the continuous residence calculation.
• Heredia v. Sessions, Ardon v. Attorney General of United States, and Calix v. Lynch: These Circuits upheld similar interpretations, reinforcing the majority's stance.
• Rimini Street, Inc. v. Oracle USA, Inc.: Highlighted that statutory redundancy does not override clear legislative intentions.

3.2 Legal Reasoning

The Court's reasoning hinged on the statutory language of 8 U.S.C. §1229b(d)(1)(B), which prohibits cancellation of removal if the LPR has committed an offense referred to in §1182(a)(2) that renders them inadmissible or removable. The majority interpreted "inadmissible" as a status that can be triggered by certain offenses regardless of whether those offenses are the direct cause of removal. This aligns with how §1182(a)(2) offenses are treated in other statutory contexts, where conviction of such offenses renders a noncitizen inadmissible independent of removal proceedings.

3.3 Impact

This decision solidifies the interpretation that prior §1182(a)(2) offenses within the first seven years of residency inherently disqualify LPRs from obtaining cancellation of removal, irrespective of whether those offenses were the direct cause of their removal. This has significant implications for LPRs with criminal histories, as it restricts their avenues for relief and emphasizes the seriousness with which immigration law treats prior criminal conduct.

4. Complex Concepts Simplified

4.1 Cancellation of Removal

A form of relief that allows certain noncitizens facing removal to remain in the United States. It is discretionary and subject to strict eligibility criteria.

4.2 §1182(a)(2) Offense

Refers to crimes involving moral turpitude or other specified serious offenses that render a noncitizen inadmissible to the U.S.

4.3 Stop-Time Rule

A statutory provision that halts the continuous period of residency required for certain immigration benefits when an individual commits a qualifying offense.

5. Conclusion

The Supreme Court's decision in Barton v. Barr underscores the stringent limitations placed on LPRs seeking cancellation of removal in the face of prior serious criminal offenses. By affirming that §1182(a)(2) offenses within the initial seven years of residency disqualify individuals regardless of their role in the removal proceedings, the Court has reinforced the role of criminal history in immigration adjudications. This ruling reiterates the balance immigration law strikes between allowing noncitizens to establish lives in the U.S. and protecting public safety by excluding those with significant criminal backgrounds.