California Case Summaries

Prasomsy v. Albarran — Temporary restraining order restores supervised immigrant’s release

Unreported / Non-Citable

Case
Prasomsy v. Albarran
Court
U.S. District Court — Northern District of California
Judge
JACQUELINE SCOTT CORLEY (Joseph R. Biden, 2022)
Date Decided
2026-09-08
Docket No.
3:26-cv-09534
Status
Unreported / Non-Citable
Topics
temporary restraining order, ICE detention, order of supervision, due process, habeas corpus

Background

Philip Prasomsy had been released under an ICE order of supervision for nearly ten years before officers re-detained him. He sought an emergency temporary restraining order restoring the longstanding status quo while the court considered his habeas and due-process claims.

The ruling addresses the dispute at its current procedural stage and does not resolve issues the court expressly left for later proceedings.

The Court’s Holding

The court granted temporary relief and ordered restoration of his release pending further proceedings. Years of supervised liberty supported a serious due-process claim, and continued detention created irreparable harm. The balance of hardships and public interest favored preserving the pre-arrest arrangement while the government responded.

The result follows from the governing pleading, jurisdictional, or merits standard applied to the record before the court.

Key Takeaways

  • Emergency relief can be available when ICE re-detains a compliant person after a long period of supervised release.
  • Counsel should document the client’s release history, compliance, community ties, and the absence of a meaningful pre-detention process.
  • Practitioners should preserve the documents and technical evidence needed to prove the rule applies to the client’s specific facts.

Why It Matters

Emergency relief can be available when ICE re-detains a compliant person after a long period of supervised release. Counsel should document the client’s release history, compliance, community ties, and the absence of a meaningful pre-detention process.

The decision is unreported and may be persuasive rather than binding, but it offers a current view of how a Northern District of California judge is applying these rules.

Read the full opinion (PDF) · Court docket

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