Precedents Cited

The Court extensively analyzed previous cases to support its interpretation of "questions of law." Notably:

• NEITZKE v. WILLIAMS, 490 U.S. 319 (1989): Discussed the dismissal of claims based on a dispositive issue of law.
• MITCHELL v. FORSYTH, 472 U.S. 511 (1985): Addressed whether certain factual determinations constitute questions of law.
• NELSON v. MONTGOMERY WARD & Co., 312 U.S. 373 (1941): Explored the classification of questions involving the effect of admitted facts as questions of law.
• INS v. St. Cyr, 533 U.S. 289 (2001): Important for understanding the limits of judicial review in immigration cases and the role of the Limited Review Provision.

Additionally, the Court referenced legislative history and lower court rulings, such as Lugo-Resendez v. Lynch, 831 F.3d 337 (2016), which had previously interpreted the 90-day time limit for reopening proceedings.

Legal Reasoning

The majority reasoned that the statutory term "questions of law" should reasonably include the application of legal standards to established facts, especially when such interpretations align with the statutory language and legislative intent. The Court emphasized the following points:

• Statutory Interpretation: The Court found no language in the statute that expressly excludes the application of law to settled facts from being considered a question of law.
• Presumption Favoring Judicial Review: There exists a strong presumption in favor of judicial review of administrative actions unless Congress clearly indicates otherwise.
• Contextual Analysis: The Limited Review Provision is part of a broader framework meant to substitute habeas corpus proceedings, thereby necessitating the inclusion of mixed questions of law and fact.
• Legislative History: Congress aimed to provide an "adequate substitute" for habeas review, which traditionally included the application of legal standards to facts.

The majority concluded that restricting judicial review to only "constitutional claims or questions of law" without including mixed questions would impede meaningful judicial oversight and violate the presumption of reviewability.

Impact

The decision in Guerrero-Lasprilla v. Barr has significant implications for immigration law and judicial review processes:

• Expansion of Judicial Oversight: By allowing courts to review the application of legal standards to established facts, alien petitioners gain a broader scope for challenging removal orders.
• Equitable Tolling: The ruling facilitates the reopening of removal proceedings beyond the standard 90-day window when due diligence can be demonstrated, thereby offering more flexibility to petitioners.
• Limitation on Administrative Discretion: Agencies like the Board of Immigration Appeals face increased accountability, as their factual determinations can be scrutinized under legal standards.
• Precedential Value: Future cases involving the interpretation of "questions of law" within similar statutory frameworks will likely reference this decision, solidifying its role in limiting the scope of jurisdiction-stripping provisions.

Moreover, the decision underscores the judiciary's role in ensuring that statutory provisions do not inadvertently eliminate essential avenues for legal redress, thereby maintaining the balance of power between legislative intent and judicial interpretation.

Equitable Tolling

Equitable Tolling is a legal doctrine that allows individuals to exceed statutory deadlines for filing claims or motions under certain circumstances. To qualify, the petitioner must demonstrate that they exercised due diligence in attempting to comply with the deadline but were prevented from doing so by extraordinary circumstances.

Questions of Law vs. Questions of Fact

Questions of Law pertain to the interpretation and application of legal principles and statutes. In contrast, Questions of Fact involve the determination of factual matters within a case, such as what exactly transpired during an event.

A Mixed Question of Law and Fact incorporates elements of both. For example, determining whether a party has acted with due diligence involves assessing factual circumstances (did they try to file on time?) and applying legal standards (what constitutes due diligence?).

Limited Review Provision

The Limited Review Provision in §1252(a)(2)(D) restricts judicial review of removal orders based on certain criminal offenses to only "constitutional claims or questions of law." This means that not all aspects of the Board's decision are open to appellate review—only those related to legal interpretations or constitutional issues.

Jurisdiction-Stripping Provistion

A Jurisdiction-Stripping Provision is a statutory clause that limits the authority of courts to hear certain types of cases. In the context of immigration law, such provisions aim to narrow the scope of judicial review available to aliens facing removal proceedings.