20-437, 593 U.S. ___ (2021) was a United States Supreme Court case that dealt with the three requirements under which a deportation order may be dismissed, as listed in 8 USC § 1326(d).

[1] In 1990, the respondent, Refugio Palomar-Santiago, was granted lawful permanent resident status, colloquially known as a green card.

[2] The Ninth Circuit based their decision on United States v. Ochoa (2017), a Court of Appeals case decided by the Ninth Circuit, which held that a noncitizen may be excused from meeting the first two requirements of 8 USC § 1362(d), given that the noncitizen was deported for an offense now considered a non-deportable offense.

[3] An aggravated felony is a term that describes a category of criminal offenses that carry consequences for noncitizens.

[4] A crime of violence is included in the list of criminal offenses that are considered an aggravated felony.

[5] At the time of Palomar-Santiago's deportation in 1998, a DUI was considered a crime of violence, and thus an aggravated felony.

The Court found this argument unconvincing because Ross v. Blake does not state that the "substantive complexity of an affirmative defense" alone does not make further administrative review unavailable.

"[1] Additionally, the Court found the Ninth Circuit's decision in United States v. Ochoa (2017) to be incompatible with the § 1326(d) statute.