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Lyle Denniston

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Constitution Check: Can the Courts Overturn New Deportation Reprieve?

Posted: 06/18/2012 4:49 pm

Lyle Denniston looks at the chances of success for a threatened lawsuit from GOP Rep. Steve King over the Obama administration's latest immigration-policy moves.

The statement at issue:

"Americans should be outraged that President Obama is planning to usurp the constitutional authority of the United States Congress and grant amnesty by edict to 1 million illegal aliens....I believe the American people will reject President Obama for his repeated efforts to violate the constitutional separation of powers."

- Iowa Republican Rep. Steve King in a statement June 15 reacting to the Obama Administration just-announced plan to postpone potential deportation of undocumented immigrants who came to the U.S. as children and have remained law-abiding. Congressman King later announced on the Mike Huckabee radio program that he is planning to "bring a lawsuit and seek a court order to stop implementation of this policy."

We checked the Constitution and...


Article III, the part of the Constitution that gives the federal courts their powers, is a major barrier to Rep. King's lawsuit and very likely will lead to its dismissal in court. Article III regularly has been the basis for federal courts' refusal to get into the middle of "separation of powers" conflicts between members of Congress and the White House.

No federal court has authority to decide any lawsuit unless it involves an actual "case or controversy," and that means that the lawsuit must have been filed by someone who will suffer some specific kind of legal injury from government action, and it must have been the type of injury that can be fixed by a court ruling.

It has seldom been the case that a member of Congress, feeling that that member's legislative powers or those of the House or Senate as a whole have been compromised or undermined, has been able to prove actual legal harm. The almost routine reaction of the courts has been that battles won or lost in the legislative arena are not to be mediated by the courts. And, at times, the courts have added in such a case that an individual may not sue if that person has no grievance that is nto shared by virtually everybody in the country -- in Rep. King's case, a claim of presidential usurpation of congressional power.

The congressman's lawsuit will also encounter in court the very specific efforts that the Obama Administration had made to insulate what was being done from court review, by framing the temporary reprieve of deportation of young undocumented immigrants as an exercise of traditional Executive power: that is, how to enforce an existing law day to day.

"Now let's be clear," the President said at the White House: "This is not amnesty, this is not immunity. This not a path to citizenship. It's not a permanent fix. This is a temporary stopgap measure that lets us focus our resources wisely..." The White House also was careful to point out that the President himself had taken no action; he issued no Executive Order, leaving the enforcement decision to be made by the Homeland Security officials who carry out immigration laws.

Homeland Security Secretary Janet Napolitano echoed those remarks:

The memorandum confers no substantial right, immigration status or pathway to citizenship. Only the Congress, acting through its legislative authority, can confer these rights. It remains to the executive branch, however, to set forth policy for the exercise of discretion within the framework of the existing law.

These arguments are a form of a traditional claim of criminal prosecutors when they decide for or against going ahead with a specific charge: it is their choice to make. (A recent example of this, of course, was the Justice Department's refusal to seek a new trial of former Senator John Edwards on charges of violating campaign finance laws after the first effort largely failed.) Being in the U.S. illegally is itself a crime, and forced deportation can result. DHS two years ago adopted a policy of giving top priority on who gets deported to those who have committed crimes or pose threats to public safety. Under the new policy, no young person in that category is eligible for the reprieve.

Courts customarily do not second-guess the use of "prosecutorial discretion," unless that has been done in a "malicious" way that is somehow discriminatory or punitive in a special way.

What rankled Rep. King, and other members of Congress, was that Congress itself had refused last year to pass the so-called "DREAM Act" that would have achieved the same kind of deportation reprieve, so -- they argued -- the President was defying congressional will in going ahead on his own.

But the failure to pass legislation, or the explicit refusal to enact a bill, does not limit Executive discretion in enforcing laws already on the books. Congress does have the power, of course, to pass a new piece of legislation to undo what DHS did last week. But the votes are not there to do that and, in any event, such a bill would be subject to presidential veto even if it had cleared Congress.

Republicans, of course, were also troubled about the politics of the new policy: they said it was timed to have an impact on this year's election, in a blatant bid by the President for support from Hispanic voters. But that, too, is an argument that courts do not attempt to settle.

Lyle Denniston is the National Constitution Center's Adviser on Constitutional Literacy. He has reported on the Supreme Court for 54 years, currently covering it for SCOTUSblog, an online clearinghouse of information about the Supreme Court's work.

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HUFFPOST SUPER USER
Willie12345
03:50 PM on 06/21/2012
Obama's decision is not law and as such can be easily changed. Sadly, it's nothing more than a political ploy.
10:49 PM on 06/19/2012
And if the rank and file DHS employees refuse to acknowledge this supposed policy like they ignored the last "prosecutorial discretion" attempt, what then? The President would look like a pandering politician AND an ineffectual leader. Better to enforce the law as written, than to use linguistic tricks to do something that is obviously not meant to be sanctioned by the law. Is this the same legal theory that worked so well during the hearings at the Supreme Court in the case of SB1070?
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voyager48
Illegitimi Non Carborundum
12:27 PM on 06/19/2012
The libs are so smug and trying to rub everyone's noses in why they cannot overturn this directive that they are actually outlining the case of what it woudl take to get it overturned.

Firstly the issue that Obama cannot duck is that he cannot unilaterally rewrite the law. So dreamers are way exposed if he does not get re-elected. That to me is the political poly right there "Note to illegals - now you have to reelect me or face reversing this directive". Well that is simply a matter of time.

Secondly Dennison outlines the circumstances it would take to make a valid case. So I am sure there are many already under way doing just that! never say never!

lastly Obama has shown his true colors and firmly set the resolve of those who are tired of his constant disregard for his constituents and Americans in general. This before an election will be significant. And I am sure that as with the Wisconsin recall the liberal press will be so busy trying to talk the game up and tell people what to believe, that they will again be unable to get out of their own way and be off the mark - delivering an unhappy surprise to Obama and those that support his underhanded tactics.
MThomasNC
Retired, Sassy, Senior Citizen
01:00 PM on 06/19/2012
You are a disgruntle GOP who got out flanked. Why can't these people get some reprieve from this country that they love.
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voyager48
Illegitimi Non Carborundum
02:40 PM on 06/19/2012
Because we are simply sticking band-aids over a problem that is far from resolved. This is in effect re-writing the law and in direct conflict with the law as written.

It is going to have unforeseen consequences like - to take advantage of the dispensation, they will have to conclusively prove illegal entry. Their families will then be exposed for having entered illegally too - thereby providing proof of their illegal entry and actions - exposing them to prosecution and possible deportation. Is Obama now going to extend protection to them too - and where does that end because that is starting to look awfully like blanket amnesty?

Also per the Morton Memo ICE has to actual discretion and is bound to apply the law as written - thereby exposing ANY illegal to the full force of the law as written. So yes there can be no guarantee that people that apply for this dispensation will not wind up being deported.

Also giving these people work permits is contingent upon them having an employer willing to sponsor them - not always as easy as it sounds. Also should the work permit not be renewed as it probabnly won't if Obama does not get reelected - they are now in in the system and can be more easily targeted for deportation.
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HUFFPOST SUPER USER
markspence
08:46 PM on 06/19/2012
Where did you get the idea that these people love the United States or care about its values?

Many illegals I know are fiercely nationalistic. That is not per se evil, but you and a number of other Americans are being narcissistic if you believe that illegals venerate the same values we do, such as the separation between church and state.

These people and their parents did not unlawfully enter this country because they love the Liberty Bell.
09:45 AM on 06/19/2012
Denniston may be right about the chances of getting Obama's maneuver overturned in court, but that doesn't make it any less unconstitutional, or any less political. What has changed in the months since he said he lacked the power to do precisely what he just did, but a political campaign? If he was really interested in getting immigration reform passed instead of trolling for votes, he would have gotten behind Rubio's efforts to actually pass legislation, instead of undercutting him and making it impossible to get anything passed this year. If I was Romney, I would be making just that case in campaign commercials.
MThomasNC
Retired, Sassy, Senior Citizen
01:03 PM on 06/19/2012
Didn't you read the article? Guess not. It was the Homeland Security Office that pulled by the deportation of these dreamers, not the president.
01:22 PM on 06/19/2012
So President Obama hasn't been all over the news taking credit for it? Or has he been taking credit for someone else's initiative instead?
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HUFFPOST SUPER USER
markspence
08:48 PM on 06/19/2012
Are you saying that DHS made this policy on its own and the White House had no say in the matter?
08:53 AM on 06/19/2012
Obama does not have the power to write the law or change the law. A represenative of the people have the right to challange this as it effect the chances of legal americans to get a job or get in college as these illegal take thier spots and jobs. You seem to try to reinvent the powers of each branch to fit your needs. Please try to keep to all the facts and state what powers each branch has and who has the right to do what. If you want to write fairy tales apply to mother goose.
MThomasNC
Retired, Sassy, Senior Citizen
01:09 PM on 06/19/2012
Boo, boo. Looks like you are too angry about something's that not true. It was Homeland Security, not the president who made the decision to stop the deportation of dreamers. I love it when GOP gets upset about their manufactured canards on what is allegedly have happened.
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04:14 AM on 06/19/2012
Clearly, Denniston is correct.

If Obama is acting outside the law, Steve King's assertion that "Obama is planning to usurp the constitutional authority of the United States Congress..." is still arrogant because Congress is not
the final arbitrator of what is unconstitutional - that authority rests with the Courts. Other than the Courts, the only redress for Congress is impeachment, and that is unlikely.

The Obama Administration may have outsmarted the GOP on this issue. Obama is simply
electing not to prosecute the law; an inaction which itself is not a crime. He is subject to criticism
for not enforcing the law, but that only has political ramifications. And the politics may well be in
Obama's favor because the GOP has dallied too long on immigration policy due to division within
its own ranks on this issue.
MThomasNC
Retired, Sassy, Senior Citizen
01:13 PM on 06/19/2012
Excellent point and I agree. He outflanked them. GOP is the party stopping immigration reform, dreamers reform. Sure it's political, what isn't. Wasn't GOP decision in 2009 to defeat Obama at every turn political.
03:12 AM on 06/19/2012
Just because it is hard to prevail in a suit doesn't make what he repeatedly does right. Americans of all political stripes are disturbed by this president's repeated abuse of power and violation of separation of powers doctrine. Even if you agree with him in this particular instance, think twice about voting for someone who is not respectful of our system of government. A vote for Obama is an endorsement of his abuse of power and sets a bad precedent for the next president just like Bush's abuses emboldened Obama's bad acts.

Obama’s policy strategy: Ignore laws

http://www.politico.com/news/stories/0612/77486.html

10 reasons the U.S. is no longer the land of the free

http://www.washingtonpost.com/opinions/is-the-united-states-still-the-land-of-the-free/2012/01/04/gIQAvcD1wP_story.html
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AlfredE69
Liberty Lovin' Tree Hugger
07:23 AM on 06/19/2012
Thank you for the links. What Constitution did Obama study; China's?
01:23 AM on 06/19/2012
Anybody got any guesses as to which demographic/psychographic/gender/geographic group will be the next focus of our Pander in Chief?
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voyager48
Illegitimi Non Carborundum
07:50 PM on 06/18/2012
1 or two maybe, but affording rights to a whole class of people in direct contradiction to federal laws sound a lot like re-writing federal laws to me. This will be the subject of vigorous reaction!
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voyager48
Illegitimi Non Carborundum
06:28 PM on 06/18/2012
Also if the pro-illegal lobby can claim racial profiling damages against SB1070 even before it goes into effect and can be proven to cause such damages - then any injunction against this initiative must be heard by the Supreme Court.
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HUFFPOST SUPER USER
BeasTT
10:50 AM on 06/20/2012
Good luck proving that. SB 1070 will hold up, this entire amnesty move is to soften up the blow for Latinos.
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voyager48
Illegitimi Non Carborundum
06:25 PM on 06/18/2012
If it was just one or two - maybe, but affording a whole class of people the right to stay in the country and work, when federal law specifically states that this is not permitted sounds awfully like changing the law. I would say that by your definition, any unemployed citizen have the right to lay suit since they will either be directly discriminated against or adversely affected by this change in policy and will be able to prove damages if even one illegal immigrant take a job that they could have done.

And that does not even begin to go into the expenses, time and hoops that legal immigrants have had to go through.

I think they have made a bad cheap politically motivated move and will find out about it soon enough!