argument next in case 25-5, Nome versus Ootrallado. Mr. Surrey.

Mr. Chief Justice, and may it please the Court, respondent's position is that when Congress

said arrives in the United States, it meant stopped outside the United States.

That theory is wrong for the simple reason that it defies the statutory

text. You can't arrive in the United States while you're still standing in Mexico. That should be

the end of this case. But even if you see some ambiguity in the text, the Court's decision in

sale should clinch the case for us.

In sale, this Court determined that the protections of the Refugee Convention and the withholding of deportation statute do not extend to aliens outside the United States

and further that it is entirely lawful for the executive branch

to prevent aliens from reaching

U.S. soil and claiming those protections.

If Congress meant to depart from that territorial approach when it adopted the statute here

just three years after sale, it would have said so.

It didn't.

This Court should, therefore, uphold the metering policy and

reverse the Ninth Circuit's judgment.

Are there treaty obligations that are implicated by either the metering policy or the issues here?

No, there are not, Justice Thomas.

Respondents rely primarily here on the refugee convention and the protocol.

But there are two reasons for which those don't apply in this case, and those aren't violated by metering.

The first is, as this Court held in sale, those provisions simply don't apply extraterritorially. They apply to the

return of someone from the United States, not to, in sale, the return of Haitian refugees

...