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The Supreme Court's decision in INS v. St. Cyr was unusual. Enrico St. Cyr was the first immigrant in a decade to prevail over the Immigration and Naturalization Service ("INS") at the Court. He was also one of a very few habeas petitioners to win before the Court in recent years. On an interpretive level, INS v. St. Cyr is also the rare immigration case in which history seemed to matter and, as Daniel Kanstroom observes in this issue, immigration law's notorious "plenary power doctrine" did not.

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