The Fate of "Unremovable" Aliens Before and After September 11, 2001: The Supreme Court's Presumptive Six-Month Limit to Post-RemovalPeriod Detention

Abstract

This Comment will address the controversial issue presented in Zadvydas, and the Supreme Court's resolution of this issue. Part II will provide a brief background of immigration law in the United States, and will explore the divergent interpretations of the IIRIRA in the Fifth and the Ninth Circuits. Part III will explore the Supreme Court's decision in Zadvydas v. Davis. Part IV will address the possible judicial, societal, and legislative impact of the Court's decision.