Two important rules of law emerging from Lieggi are that deportation is punishment, and that deportation for a marijuana conviction can be cruel and unusual punishment. When coupled with the accelerated pace of statutory reform regarding marijuana, as well as with several recent Supreme Court decisions expanding the constitutional rights of aliens in other areas, the Lieggi decision hopefully will be applied liberally.
Stephen H. Legomsky,
Deportation of an Alien for a Marijuana Conviction Can Constitute Cruel and Unusual Punishment: Lieggi v. United States Immigration and Naturalization Service, 389 F. Supp. 12 (N.D. Ill. 1975),
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol13/iss2/11