Clark v. Martinez, 543 U.S. 371 (2005), was a United States Supreme Court case ending the detention of people who had been denied refugee status.

[3] The case resolved conflicting rulings made by the 9th and 11th circuits on whether Zadvydas v. Davis (2001)[4] was applicable to inadmissible immigrants, Sergio Martinez and Daniel Benitez.

Zadvydas v. Davis stated that the government can detain admissible and admitted aliens only long enough beyond the 90-day removal period if necessary for deportation.

[6] Cubans Sergio Suarez Martinez and Daniel Benitez gained access to the US in June 1980 via the Mariel Boatlift.

While being detained by INS, Martinez and Benitez, each filed a petition for a writ of habeas corpus to challenge their indefinite detention.

The United States Coast Guard began to see numerous personal vessels flood out of Key West and Miami, Florida.

Not long after their departure for Mariel the Coast Guard began to receive distress calls and several search and rescue mission were required.

Zadvydas v. Davis ruled that admissible aliens/ aliens who had already been granted US residency facing deportation may not be detained longer than the 90-day removal period.

[12]Kennedy's objection—that Zadvydas might be read to overturn prior cases and Constitutionally forbid the indefinite detention of aliens seeking "initial admission to this country"—was the question presented in Clark v. Martinez.

One of the government's tactics has been to deny release to people who are "paroled" into the United States, meaning that they are physically allowed into the country while their status is being determined.