CSS
Catholic Social Services, Inc. v. Reno (CSS) is a Ninth Circuit case concerning an Immigration and Naturalization Service (INS) regulation that required undocumented immigrants to obtain INS permission before departing the United States (even for a brief or casual absence), if they wished to preserve eligibility for legalization under the Immigration Reform and Control Act of 1986 (IRCA).
The plaintiffs, representing a class of immigrants, filed a class action lawsuit in 1986 challenging the regulation. They argued that the rule unlawfully restricted eligibility for legalization by penalizing otherwise qualified individuals who had briefly left the country without advance parole. See: Catholic Social Services, Inc. v. Meese, 685 F. Supp. 1149 - Dist. Court, ED California (1988).
The case proceeded through multiple rounds of litigation and ultimately reached the U.S. Supreme Court in Reno v. Catholic Social Services, Inc., 509 U.S. 43 (1993). There, the Court vacated earlier lower court rulings on the grounds that the plaintiffs' claims were not yet ripe for review.
Upon remand, the Ninth Circuit again reviewed the case in 1997 and dismissed the plaintiffs' claims for lack of standing, citing statutory changes that restricted judicial review. As a result, the INS regulation remained in effect. See: Catholic Social Services, Inc. v. Reno, 134 F. 3d 921 - Court of Appeals, 9th Circuit (1997).
However, the Ninth Circuit revisited the issue in a subsequent case, Catholic Social Services v. I.N.S. (2000), and ruled in favor of the plaintiffs. Despite this later favorable decision, its practical impact was limited. In 2000, Congress enacted the Legal Immigration Family Equity (LIFE) Act, which amended the law to allow affected individuals to adjust their status, effectively granting the relief that plaintiffs had long sought.
[Last reviewed in June of 2025 by the Wex Definitions Team]
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