Garcia v. Attorney General of US

FUENTES, Circuit Judge,

dissenting:

In 1996 Rosalba Garcia was granted permanent residency, based in part on a sworn statement falsely claiming that Dinorah Landestoy, a U.S. citizen, was her mother. Landestoy was, in fact, her aunt. Eight years later, DHS learned of the deception and, determining Garcia was never lawfully admitted, commenced removal proceedings. The majority reasons that, despite her false statement, Garcia cannot be removed because more than five years have passed since her fraud occurred. However, I believe that under a plain reading of § 246(a), Garcia is removable because § 246(a)’s five-year period applies only to rescissions and not to removal actions. Notably, that was the opinion of the Fourth Circuit in Asika v. Ashcroft, 362 F.3d 264 (4th Cir.2004), the only other circuit court case to address this provision since its amendment in 1996. Moreover, I believe that Bamidele, upon which the majority relies, does not apply to Garcia’s removal proceeding and is no longer binding in light of the 1996 amendment. Therefore, I respectfully disagree.

I.

By its own terms, § 246(a) expressly applies its five-year time limitation only to when the “Attorney General shall rescind” the adjustment action. 8 U.S.C. § 1256(a) (emphasis added). As the Fourth Circuit explained in Asika, “Section 246(a) itself gives no indication that its five-year limitation restrains the Attorney General’s deportation authority, and the provisions of the Act that govern deportation refer neither to section 246 nor the statute of limitations that it purportedly creates, nor, for *730that matter, to any time limitation on deportation at all.” 362 F.3d at 269.

This, I believe, is the more appropriate plain reading of § 246(a). Reinforcing this construction is the fact that the public laws enacting and amending this provision respectively describe its subject as “Rescission of adjustment of status,” Pub.L. No. 82-414, 66 Stat. 164, 217 (1952) (emphasis added), and “Rescission of lawful permanent resident status.” Pub.L. No. 104-208, 110 Stat. 3009-619, 3009-649 (1996) (emphasis added); see also H.R.Rep. No. 82-1365, at 63 (1952), U.S.Code Cong. & Admin.News 1952, p. 1653 (describing section’s effects and making no mention of removal).

The 1996 amendment of § 246(a) confirms that the five-year bar is meant to apply only to rescission proceedings. The sentence added to the provision in 1996 reads, “Nothing in this subsection shall require the Attorney General to rescind the alien’s status prior to commencement of procedures to remove the alien under section 1229a of this title, and an order of removal issued by an immigration judge shall be sufficient to rescind the alien’s status.” 8 U.S.C. § 1256(a). This amendment shows that rescission proceedings, to which the five-year limitation period applies, have no bearing on the Attorney General’s authority to commence a removal action. Thus, when DHS learned that Garcia was never lawfully admitted, based on her fraudulent statement, the government could properly commence removal proceedings even though more than five years had passed since she was granted permanent residency.

II.

The majority’s reliance on Bamidele in departing from this plain language is misplaced because the circumstances surrounding the removal here are quite different. In Bamidele, the government became aware of the alien’s removability within five years of his adjustment of status yet failed to act. In this case, the government did not realize Garcia had made a misrepresentation until that five year window had expired.6 To deny removal in this case would reward Garcia for the successful concealment of her fraud.7

Furthermore, we have the authority to reevaluate the otherwise controlling interpretation of a statute where its language has subsequently been amended. See Reich v. D.M. Sabia Co., 90 F.3d 854, 858 (3d Cir.1996). The 1996 amendment had been enacted, but was not yet effective when Bamidele was issued. Bamidele did not discuss the pending amendment. But even before the 1996 amendment, other courts applying § 246(a) were not tempted *731to expand its time limitation beyond the arena of rescission. See Choe v. Immigration & Naturalization Serv., 11 F.3d 925, 928 n. 4 (9th Cir.1993) (“The bottom line is § 246 does not prevent the removal of adjusted aliens.”); Ubiera v. Bell, 463 F.Supp. 181, 185 (S.D.N.Y.1978) (“[P]lain-tiff may be subject to deportation proceedings even if the five-year limitation in Section 246(a) is applied to him.”). Bami-dele’a contrary holding rested on the rationale that, since the BIA conducts rescission and removal proceedings in the same way, it would be unreasonable for the statute to treat them differently. 99 F.3d at 564-65. However, the 1996 amendment, which was not discussed in Bami-dele, indicates that Congress does not view rescission and removal as equivalents. As the Fourth Circuit noted in Asika v. Ashcroft, the Immigration and Nationality Act (“INA”) guarantees certain procedural safeguards for removal proceedings that are not put in place for rescissions. See 362 F.3d at 270 (comparing 8 U.S.C. §§ 1229a, 1256). Congress’s grant of permission to substitute a removal proceeding for removal and rescission suggests that the more extensive procedural protections associated with removal render the less formal step of rescission unnecessary. Although currently the two types of proceedings are conducted almost identically, that approach is at the discretion of DHS, and therefore would leave a role for § 246(a) should the agency revert to the disparate procedures permitted by the INA. Id. at 270 & n. 7; In re S — , 9 I. & N. Dec. 548, 555 n. 8 (BIA 1961).

Our adherence to the interpretation in Bamidele has placed us out of step with every other circuit to address § 246(a), both before and after the 1996 amendment. As noted above, we are the only circuit to interpret § 246(a) to apply to removal proceedings before the 1996 amendment. Since then, the Fourth Circuit has rejected Bamidele outright in Asi-ka. The Eleventh Circuit has also implicitly endorsed removal actions occurring outside the five-year window in Savoury v. Attorney General, 449 F.3d 1307 (11th Cir. 2006), stating: “What § 246(a) does is establish a five-year statute of limitations for the Attorney General to bring rescission proceedings and further clarifies that an [immigration judge’s] order of removal may also act as a rescission of status even if it is issued after that five year period. ” Id. at 1314 n. 2 (emphasis added).

The majority contends that if its interpretation of § 246(a) creates an anomaly in the application of the INA, Congress is free to eliminate that anomaly. However, that argument fails to consider the history of this statute. At the time that Congress amended the INA, those authorities that had addressed the scope of § 246(a) had held it to govern only rescissions, not removals. See, e.g., Oloteo v. Immigration & Naturalization Serv., 643 F.2d 679 (9th Cir.1981); Ubiera v. Bell, 463 F.Supp. 181, 185 (S.D.N.Y.1978); In re S — , 9 I. & N. Dec. 548 (BIA 1962). Under the majority’s logic, if that opposing interpretation were anomalous, the legislature would have addressed it in 1996. Compare Olo-teo, 643 F.2d at 683 (“The argument that our interpretation of § 246(a) renders it without practical effect would best be made before Congress and the Attorney General.”). Instead, Congress enacted an amendment that at the very least left the issue unclear, and that I believe indicates an understanding that § 246(a) applies only to rescission.

III.

I do not rest my dissent on the position that we must grant Chevron deference to the BIA’s construction of § 246(a), as I believe Congress’s intent is clear on the *732face of the statute and “that is the end of the matter.” Chevron, U.S.A., Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). However, it is in situations such as these that an agency’s view of a statute it administers may be helpful to our interpretive task. As is evident from this Court’s discussion in Bamidele, the application of the statute of limitations contained in § 246(a) requires consideration of matters well within the agency’s expertise, including the correct value to place on the durability of an alien’s permanent status, 99 F.3d at 564, and the difference between rescission and removal proceedings. Id. at 564-65; see also Asika, 362 F.3d at 271 n. 8. The BIA’s input is particularly persuasive in that it is consistent with the statute’s plain language. Compare Lynch v. Lyng, 872 F.2d 718, 724 (6th Cir.1989) (“Here, where we find that the language of the statute, the broader purposes, and the legislative history argue against the Secretary’s position, we are not compelled to defer to his interpretation.”); Dion v. Sec’y of Health & Human Servs., 823 F.2d 669, 672-73 (1st Cir.1987) (refusing to defer to agency interpretation where it was inconsistent with Congress’s explicit and implicit intent); In re Oliver M. Elam, Jr., Co., 771 F.2d 174, 181 (6th Cir.1985) (rejecting agency interpretation that has “no support in the plain language of’ the relevant provision) (all cited by Bamidele in support of decision not to defer to the Attorney General’s construction of § 246(a)).

Moreover, were we to view the BIA’s decision through the lens of Chevron deference, Bamidele would clearly no longer be binding. In Bamidele itself, we stated that “We express no opinion as to whether ... any other subsequent amendments to the Act would make someone in Bamidele’s position deportable.” 99 F.3d 557, 565 (3d Cir.1996). Although the 1996 modification was not a drastic one, it offered a reasonable basis for the BIA to reject Bamidele as no longer applicable, and we should defer to that decision.

IV.

In short, I believe the majority’s decision strays impermissibly far from the language of § 246(a). The plain meaning of the statute is supported by logic, the view of other circuits, and the BIA’s own reading. Further, I believe that Bamidele has lost its precedential value in light of the 1996 amendment of § 246(a)’s language. For these reasons, I respectfully dissent.

. It is true that Landestoy had filed three previous petitions in 1985, 1993, and, 1995 seeking to have .Garcia recognized as her daughter for immigration purposes, all of which did not succeed because Landestoy could not prove she was Garcia's mother. (See App. 30 (1985 petition); App. 35 (1993 petition); App. 42 (1995 petition).) The government’s contention that it did not discern Garcia's fraud before she applied for naturalization because the earlier applications were filed under different names is not supported by the record. However, there is no evidence that DHS was aware that these petitions applied to the same person. This seems simply to have been a case of the right hand not knowing what the left hand was doing, as evidenced by the fact that DHS allowed Lan-destoy to file the 1996 petition while the 1995 petition was still pending, and approved the former on September 19, 1996 just a week before denying the latter on September 26, 1996.

. A non-precedential opinion of this court, De Deguzman v. Attorney General, 263 Fed.Appx. 222 (3d Cir.2008), distinguished Bamidele on similar grounds.