INS v. Lopez-Mendoza

Adan Lopez-Mendoza and Elias Sandoval-Sanchez (defendants), Mexican citizens illegally present in the United States, were each arrested by INS agents at their workplaces. Lopez-Mendoza signed an affidavit admitting his illegal entry and never objected to its admission at his deportation hearing; the immigration judge found the legality of his arrest irrelevant and ordered him deportable, and the Board of Immigration Appeals (BIA) dismissed his appeal. Sandoval-Sanchez, after admitting his illegal presence, moved to suppress the INS's evidence as fruit of an illegal arrest; the immigration judge denied the motion and the BIA dismissed his appeal too. The Ninth Circuit reversed Sandoval-Sanchez's order, finding his detention violated the Fourth Amendment, and vacated Lopez-Mendoza's order for further Fourth Amendment findings. The Supreme Court granted certiorari.