Woodby v. Immigration & Naturalization Service

Summary

The Supreme Court held that the Government must establish the facts supporting deportability by clear, unequivocal, and convincing evidence. It distinguished the burden of proof in administrative deportation proceedings from the reasonable, substantial, and probative evidence standard governing judicial review. The Court set aside the judgments in the consolidated cases and remanded for further proceedings.

Holdings

1. The Government must establish the facts supporting deportability by clear, unequivocal, and convincing evidence before a deportation order may be entered.
2. The statutory references to reasonable, substantial, and probative evidence address the scope and quality of judicial review, not the degree of proof required of the Government before the administrative factfinder.

Questions Presented

1. What burden of proof must the Government satisfy in deportation proceedings?
2. Do the Immigration and Nationality Act provisions requiring reasonable, substantial, and probative evidence establish the administrative burden of proof, or do they govern the scope and quality of judicial review?
3. What disposition is appropriate where the administrative decisions did not clearly apply the required burden of proof?

Disposition

reversed_and_remanded