In Zadvydas v. Davis, 533 U.S. 678, 121 S.Ct. 2491, 150 L.Ed.2d 653 (2001), the Supreme Court considered habeas petitions of two individuals, Kestutis Zadvydas and Kim Ho Ma, being held pursuant to the second category of 1231(a)(6). 533 U.S. at 682-85, 121 S.Ct. 2491. Although both men were found removable, no country would accept them; as a result, the government continued to detain them for years beyond the expiration of the 90-day removal period. In support of the continued detention of these men, the government argued that they "may be detained beyond the removal period" language of 1231(a)(6) authorized indefinite detention of a removable alien. The Court, however, concluded that it did not, reasoning that continued detention would present serious constitutional problems under the Fifth Amendment's Due Process Clause. Id. at 690, 121 S.Ct. 2491. Applying the doctrine of constitutional avoidance, the court held that "once removal is no longer reasonably foreseeable, continued detention is not authorized by the statute." Id. at 699, 121 S.Ct. 2491. Zadvydas then concluded that six months was a presumptively reasonable period of detention, beyond the removal period, in which to effectuate deportation. Id. at 702, 121 S.Ct. 2491.