In Reno v. American-Arab Anti-Discrimination Comm., 525 U.S. 471, 483 (1999) ("AADC"), a group of temporary residents, who belonged to the Popular Front for the Liberation of Palestine, sought injunctive and declaratory relief on the ground that the INS was selectively enforcing the immigration laws against them in violation of their First and Fifth Amendment rights. See 525 U.S. at 473-74. The INS sought to dismiss the case for lack of jurisdiction, arguing that INA 242(g), made applicable to the case by 306(c)(1) of IIRIRA, deprived the courts of power to hear the appeal. See id. at 475. The Supreme Court agreed with the INS that INA 242(g) deprived federal courts of jurisdiction over the petitioners' selective enforcement case until the deportation orders against them became final, if ever. See id. at 482. The Court, however, rejected the "unexamined assumption that 1252(g) covers the universe of deportation claims" and held that the section covered only the three discrete actions delineated by the statute: the Attorney General's decision to commence proceedings, adjudicate cases, or execute removal orders. See id. In AADC, the Supreme Court contrasted the narrow scope of INA 242(g) with INA 242(b)(9), which it described as an "unmistakable zipper clause" that channels judicial review of all immigration-related decisions and actions to the court of appeals. Id. at 482-83. In Reno v. American-Arab AntiDiscrimination Committee, 525 U.S. 471 , 119 S. Ct. 936 (1999) (AADC), the Supreme Court warned us repeatedly that 1252(g) is to be read narrowly. The Court instructed us that 8 U.S.C. 1252(g) does not apply to the universe of deportation claims. 525 U.S. at 482, 119 S. Ct. at 943. Instead, 1252(g) applies only to three discrete actions that the Attorney General may take: her decision or action to commence proceedings, adjudicate cases, or execute removal orders. Id. (quoting 8 U.S.C. 1252(g)). Indeed to emphasize and illustrate this point, the Supreme Court listed a number of decisions and actions for which Article III jurisdiction would lie. Id. (noting that courts still can review the decisions to open an investigation, to surveil the suspected violator, to reschedule the deportation hearing, to include various provisions in the final order that is the product of the adjudication, and to refuse reconsideration of that order). This list illustrates how 1252(g) is not a shorthand way of referring to all claims arising from deportation proceedings. Id. In Reno v. American-Arab Anti-Discrimination Committee, 525 U.S. 471 (1999), the Court repeatedly characterized this statutory provision as "narrow." 525 U.S. at 482, 487. Moreover, it made clear its disapproval of the "unexamined assumption that 8 U.S.C. S 1252(g) covers the universe of deportation claims--that it is a sort of `zipper' clause that says `no judicial review of deportation cases unless this section provides judicial review.' " 525 U.S. at 482. In fact, the Supreme Court chided circuit courts for their "strained" and overly broad readings of the provision: "It is implausible that the mention of three discrete events along the road to deportation was a shorthand way of referring to all claims arising from deportation proceedings." Id. According to American-Arab, "Section 1252(g) was directed against a particular evil: attempts to impose judicial constraints upon prosecutorial discretion." Id. at 485 n.9. By way of illustration, the Court articulated a non-exclusive list of events that might seem to be contemplated by the language of S 1252(g) but are nevertheless reviewable. For example, a decision to reschedule a deportation hearing is not unreviewable under S 1252(g); neither is a decision "to include various provisions in the final order that is the product of the adjudication." Id. at 482.