On January 12, 2005, the U.S. Supreme Court issued the Clark v. Martinez decision. The Court decided that individuals under final exclusion orders cannot be indefinitely detained based on the fiction that they did not enter or achieve lawful admission to the United States. In a 2001 decision, Zadvydas v. Davis, the Supreme Court decided that individuals under final deportation orders who had entered the United States could not be detained indefinitely in situations where there was no foreseeable expectation that the deportation could be effectuated. Many of the so called Mariel Cubans, who came to the United States during the early 1980’s, had been stopped at the border and were paroled into the United States for exclusion hearings. There was a split in the Circuit Appellate Courts as to whether the Zadvydas case applied to those individuals. In a 5/4 decision, the U.S. Supreme Court extended the Zadvydas ruling to the excludable aliens, the vast majority of whom are Cuban nationals.