Define: I.N.S. V. Lopez-Mendoza

In the case of I.N.S. v. Lopez-Mendoza, the Supreme Court determined that deportation hearings are considered civil proceedings rather than criminal trials. As a result, individuals facing deportation do not have the same protections as they would in a criminal trial. The government only needs to present “reasonable, substantial, and probative evidence” in order to justify deportation. Additionally, the Court ruled that the exclusionary rule, which typically prevents the use of evidence obtained through an unlawful search, does not apply to deportation hearings. This is because the government’s objective is to prevent ongoing crimes rather than punish past offences. The Court concluded that the costs associated with applying the exclusionary rule would be too high and it would not effectively deter immigration agents. Consequently, the Court overturned the decisions made by the appellate courts and reinstated the deportation orders.

The legal case I.N.S. v. Lopez-Mendoza involved the Supreme Court of the United States ruling that deportation hearings are considered civil proceedings, and therefore the defendant’s identity cannot be suppressed even if they were subject to an unlawful arrest. The exclusionary rule, which typically applies in criminal proceedings, does not apply to deportation hearings. The case involved two respondents, Lopez-Mendoza and Sandoval-Sanchez, who were arrested by the Immigration and Naturalization Service (INS) during a warrantless search of their workplace. Both individuals were ordered to be deported by an immigration judge. The Supreme Court consolidated their cases on appeal.

In the case of Lopez-Mendoza, he sought to reverse his deportation on the grounds that the immigration judge held a hearing after an unlawful arrest. However, the majority opinion stated that the lawfulness of the arrest or subsequent interrogations are irrelevant in deportation hearings. This is because the government’s objective is to prevent an ongoing crime, rather than punish past crimes. If a crime is in progress, immigration agents have the authority to arrest the immigrant.

In the case of Sandoval-Sanchez, he sought to exclude the evidence obtained during his arrest from being used in the trial. However, the Court had not yet determined the application of the exclusionary rule in deportation hearings. The Court decided to use a balancing test to determine whether the exclusionary rule should apply. This involved weighing the social benefits of the exclusionary rule against the associated costs.

The majority opinion believed that the exclusionary rule would not have the usual deterrent effect on INS agents, as it is more valuable in criminal proceedings. Since the INS typically arrests individuals for civil deportation hearings, the majority did not see the same level of importance in applying the exclusionary rule.

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This glossary post was last updated: 16th April 2024.