Unreported / Non-Citable
Background
Angel Adonai Cruz Interiano is an immigration detainee who petitioned the Eastern District of California for a writ of habeas corpus against the warden of the Golden State Annex ICE Detention Facility. The court's November 2, 2026 order, styled a release order and signed by Judge Daniel J. Calabretta, does not recount his immigration history, the basis or start date of his detention, or the length of time he was held.
The court noted that it had already addressed the legal issues raised in the petition in earlier decisions, citing Morillo v. Albarran and E.L.D.M. v. Becerra, both decided in late 2025. Acting under 28 U.S.C. section 2243, it directed respondents to file a return showing cause why the writ should not be granted and release ordered on that same basis. Respondents answered that, in light of the Ninth Circuit's July 30, 2026 decision in Rodriguez Vazquez v. Bostock, they conceded that binding precedent establishes a statutory right to a bond hearing. The order does not describe respondents' position on the due process question or on release.
Because the order incorporates its earlier decisions by reference and those decisions were not part of the materials reviewed, the due process reasoning is available here only in the court's brief summary.
The Court’s Holding
The court granted the petition for the reasons stated in its prior orders. The only reasoning stated in this order is that, although respondents accept a statutory right to a bond hearing, the lengthy delay in providing the statutorily mandated hearing violates petitioner's due process rights and justifies release. The order does not measure the delay or walk through a due process test; it leaves that analysis to the earlier decisions.
The relief is specific. Respondents must immediately release petitioner and may not impose any additional restrictions on him unless a future pre-deprivation or custody hearing determines they are necessary. If the government wants to detain him again, it must give at least seven days' notice and hold a pre-deprivation bond hearing before a neutral arbiter under section 1226(a) and its implementing regulations, at which his eligibility for bond must be considered. Respondents must file a status report within five days confirming his release. The clerk was directed to serve the facility, close the case, and enter judgment for petitioner, and the order resolves all pending motions.
The court expressly did not decide what authority respondents would have to detain petitioner if he becomes subject to an executable final order of removal. That question remains open.
Key Takeaways
- The court treated respondents' concession of a statutory bond-hearing right under Rodriguez Vazquez as not ending the matter, because the delay in providing the hearing was itself held to violate due process.
- The remedy was immediate release rather than only an order to hold a hearing, and the order bars additional restrictions unless a later hearing finds them necessary.
- Any re-detention requires at least seven days' notice and a pre-deprivation bond hearing before a neutral arbiter under section 1226(a), at which bond eligibility is considered.
- The order does not address detention if petitioner becomes subject to an executable final order of removal.
- The order rests on earlier decisions that are cited but not reproduced, so readers should consult Morillo and E.L.D.M. for the full due process analysis.
Why It Matters
This is a short, unreported district court order, so it carries no precedential weight beyond this case and is persuasive at most. It applies the judge's earlier decisions rather than setting out new reasoning, and it binds only the parties. Its value is in showing how those earlier decisions are being applied after Rodriguez Vazquez: once the government accepts a statutory entitlement to a bond hearing, the court still examines whether the delay in providing one offends due process and, if so, ordered release rather than a belated hearing.
Several matters stay open. The order does not state how long petitioner was detained or what delay is enough to violate due process, it does not address removal-order detention, and it leaves to a future hearing whether any conditions or renewed custody are warranted. Whether the government will seek to re-detain petitioner, and whether any party will challenge the order further, is not indicated in the materials.