Review of immigration decisions
Noel Reyes Mata v. Lynch
In brief
The Supreme Court said the Fifth Circuit had authority to review Mata’s appeal, but did not decide whether his immigration case should be reopened.
- Where it stands
- Decided
Decided 8-1 · June 15, 2015 · Opinion by Justice Kagan
- What it’s about
- Noel Reyes Mata asked the Board of Immigration Appeals to reopen his immigration case, but it rejected his motion as filed too late and the Fifth Circuit declined review.
- Who it affects
- Federal appeals courts have the legal authority (jurisdiction) to review Board of Immigration Appeals denials of requests to reopen, including when the Board says a request was filed late.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that appeals courts can review such denials, overturned the Fifth Circuit’s ruling, and sent the case back to that court (remanded); it did not decide whether Mata’s case should be reopened.
Noel Reyes Mata asked the Board of Immigration Appeals to reopen his immigration case, but the Board rejected his request as late under a 90-day filing limit.
The dispute concerned a 90-day filing limit for requests to reopen immigration cases.
Question presented
Did the U.S. Court of Appeals for the Fifth Circuit err in holding that it did not have the jurisdiction to review a Board of Immigration Appeals decision not to suspend the 90-day filing limitation?
What the Court decided
Holding
The Fifth Circuit erred in declining to take jurisdiction over Mata’s appeal. A court of appeals has jurisdiction to review the BIA’s rejection of an alien’s motion to reopen. Kucana v. Holder, 558 U. S. 233, 253. Nothing about that jurisdiction changes where the Board rejects a motion as untimely, or when it rejects a motion requesting equitable tolling of the time limit. That jurisdiction likewise remains unchanged if the BIA’s denial also contains a separate decision not to exercise its sua sponte authority. 366, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said appeals courts’ authority does not depend on whether the Board rejects a request as late, refuses to excuse the deadline for fairness (equitable tolling), or separately declines to reopen a case on its own.
The vote
From the opinions
“Recharacterization is something very different: It occurs when a court treats an unambiguous filing as something it is not.”
What's next
The Fifth Circuit will take up Mata’s appeal. The Supreme Court left unresolved whether the Board should reopen his case.
Documents
Opinions
Docket activity
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Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.