On April 29, 2020, the United Kingdom Supreme Court (UKSC) released its judgment in the case of AM (Zimbabwe) v. Secretary of State for the Home Department. AM, the appellant, “is a citizen of Zimbabwe” who, “while lawfully resident [in the UK] . . . committed a string of serious crimes.” Additionally, he “is HIV positive.” AM is appealing a deportation order issued by the Secretary of State in 2007, stating “that, if deported to Zimbabwe, he would be unable to access the medication which, here in the UK, prevents his relapse into full-blown AIDS.” Early on in the process of his appeal he “relied only on rights under Article 8 [of the European Convention of Human Rights].” However, after the European Court of Human Rights released its decision in Paposhvili v. Belgium (in favor of the appellant, who “sought to resist deportation…in light of his grave ill-health”), AM “[sought] to obtain an order for a rehearing before one or other of the tribunals at which he could present a case under Article 3.” His appeal was dismissed by the Court of Appeal, which concluded that Paposhvili “reflected only a ‘very modest’ extension of the protection against return [established in N v. Secretary of State for the Home Department and N v. United Kingdom] given by Article 3 in cases of ill-health.” The Supreme Court disagreed with the Court of Appeal’s analysis, stating that “[t]he Grand Chamber’s pronouncements in the Paposhvili case about the procedural requirements of article 3...can on no view be regarded as mere clarification of what the court had previously said”; instead the decision marked a significant departure which then required the Court to depart “from the decision of the House of Lords in the N case,” “allow the appeal and to remit the appellant’s proposed claim under article 3 to be heard...by the Upper Tribunal.”