The U.S. Supreme Court case Janet Reno, Attorney General, et al. v. Catholic Social Services, Inc., et al., 1992 revolved around the Immigration and Nationality Act (INA) of 1986 which granted amnesty to certain groups of illegal immigrants in the United States. The dispute arose when the Immigration and Naturalization Service (INS) interpreted a provision that required applicants to have resided continuously in America since before January 1st, 1982 as meaning they must not have left for any reason after this date - even if their departure was brief or involuntary. This interpretation led to many being denied legal status under INA's legalization program. Catholic Social Services filed suit on behalf of several ineligible aliens arguing that INS' interpretation violated due process rights by retroactively penalizing conduct that was innocent at the time it occurred and also contradicted Congressional intent behind INA's passage. In its decision, however, the Supreme Court ruled against Catholic Social Services stating that federal courts lacked jurisdiction over such claims until all administrative remedies had been exhausted first – essentially requiring each individual alien affected by this policy to challenge it through INS procedures before seeking judicial review.

In the dissenting opinion for Reno v. Catholic Social Services, Inc., Justice Scalia argued that the court should not have jurisdiction over this case as it was essentially a dispute about an agency's interpretation of its own regulations, rather than a constitutional issue. He contended that the Immigration and Naturalization Service (INS) had acted within its authority in interpreting the Immigration Reform and Control Act (IRCA). The majority's decision to allow judicial review of such administrative decisions could lead to courts becoming inundated with similar cases challenging agency interpretations. Furthermore, he believed that allowing non-immediate relatives of legalized aliens to apply for adjustment of status without leaving the country contradicted Congress' intent when passing IRCA - which was aimed at discouraging illegal immigration by making it more difficult for undocumented immigrants to gain legal status.