Unreported / Non-Citable
Background
Inderjit Singh, an immigration detainee, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241 in the Eastern District of California on September 8, 2026. According to the order, he alleges that his continued detention violates his Fifth Amendment Due Process rights and asks for immediate release or a meaningful custody review. The order describes the real parties in interest as the Department of Homeland Security, Immigration and Customs Enforcement, and the warden of the detention facility.
Singh had previously filed Singh v. Albarran, No. 1:26-cv-0940-DC-ICD, which the order calls Singh I. That case was still pending when he began this one. The order states that Judge Coggins denied the petition in Singh I on October 1, 2026. Magistrate Judge Ila C. Deiss signed the present order on October 22, 2026, and it was entered on the docket the next day.
The Court’s Holding
The order is a procedural directive, not a dismissal. Relying on Adams v. California Department of Health Services, 487 F.3d 684 (9th Cir. 2007), the magistrate judge explained that litigants have no right to maintain two separate actions involving the same subject matter at the same time in the same court against the same defendants. A suit is duplicative when the claims, parties, and available relief do not significantly differ. Applying that test, the court stated that the claims and parties in the two actions are essentially identical. Both petitions allege Fifth Amendment Due Process violations arising from continued detention and seek release or a meaningful custody review. Although the named respondents are not identical, the court reasoned that Singh sues the same real parties in interest in both cases.
Because Singh filed this action while an essentially identical case was pending in the same court, the order concludes that this case is subject to dismissal as duplicative. The court did not dismiss it. It ordered Singh to show cause in writing, within 14 days of the date of the order, why the action should not be dismissed as duplicative of Singh I. The order does not decide the merits of the detention claims. It does not say whether any eventual dismissal would be with or without prejudice, and it does not discuss how the October 1 denial in Singh I affects the new petition. Those questions remain open pending Singh's response and a later ruling.
Key Takeaways
- A second habeas petition filed while an earlier case about the same detention is pending in the same court can be treated as duplicative, even if the captioned respondents are not identical.
- Under the Adams standard cited in the order, the court compares the claims, the parties, and the available relief to decide whether the two suits significantly differ.
- The order looks to the real parties in interest, here DHS, ICE, and the facility warden, rather than to differences in how respondents are named.
- The order is a show-cause directive that gives Singh 14 days to respond in writing; it does not itself dismiss the petition.
- The court has not ruled on the Fifth Amendment due process claim, so nothing in the order resolves whether Singh's detention is lawful.
Why It Matters
The order shows how a federal district court may screen successive immigration detention petitions for duplication before reaching the merits. The court looked past differences in named respondents to the substance of the claims, the real parties, and the relief requested, which follows the functional approach described in Adams. Detainees who file overlapping habeas actions in the same district may therefore be asked to justify the second filing.
The order is a non-final directive by a magistrate judge in a single case and adds no new precedent beyond applying existing Ninth Circuit authority. The outcome is unresolved. The court could dismiss after reviewing Singh's response, or it could allow the case to proceed if he shows a meaningful difference from Singh I. The response may also need to address that Singh I had already been denied by the time this order issued.