Santos-Zacaria v. Garland, , was a United States Supreme Court case in which the court clarified the interpretation of , a statute governing when aliens can seek federal court review of removal orders issued by the Board of Immigration Appeals (BIA). The Court held that the statute does not require noncitizens to exhaust all possible discretionary appeals within the administrative process before taking their case to a federal court. Instead, they only need to exhaust mandatory, non-discretionary administrative remedies—those they are entitled to by law. Reactions. The case was widely considered low-profile and uncontroversial, although it received some attention because of Justice Jackson's decision to use the term "noncitizen" in place of "alien" and honor the petitioner's preferred name and pronouns. While LGBTQ+ and immigrant rights groups expressed support for Jackson's phrasing, conservative sources argued that "noncitizen" was legally inaccuate and admonished the Court's majority for signing onto the decision.