Unreported / Non-Citable
Background
Juan Carlos Valle Castillo, proceeding without a lawyer, filed a petition under 28 U.S.C. § 2241 on October 8, 2026, challenging his detention by Immigration and Customs Enforcement. He also sought a temporary restraining order requiring his immediate release. The next day, the court set a briefing schedule and directed the respondent to identify any law or fact distinguishing several earlier decisions. It also asked for any opposition to deciding the underlying petition on the existing briefing and for substantive reasons supporting that position.
The respondent filed a combined opposition on October 13. It conceded that Valle Castillo was subject to 8 U.S.C. § 1226(a), but argued that the statute’s procedures and implementing regulations were constitutional, that he had to use those procedures, and that he should exhaust his administrative remedies. It did not object to a direct merits ruling. The court found that Valle Castillo was a native and citizen of Mexico who entered the United States in 1999 and had continuously resided in the country since then. ICE arrested him during a traffic stop on or about September 25, 2026.
The Court’s Holding
The court waived exhaustion, incorporating its earlier discussion in Ramirez and concluding that waiver was necessary to avoid further irreparable harm and delay in vindicating Valle Castillo’s rights. Because the respondent did not object to a direct merits ruling, the court proceeded to decide the petition on the existing briefing. On the merits, it relied on its prior explanation in Zurita Navarro that the government’s failure to follow § 1226(a) procedures warrants immediate release. The dispositive evidentiary point was narrow: there was no evidence that ICE arrested Valle Castillo pursuant to a warrant during the traffic stop, as § 1226(a) required.
The respondent also did not argue that the warrantless arrest fell within the Immigration and Nationality Act’s exception in 8 U.S.C. § 1357(a)(2). The court described that exception as permitting a warrantless arrest when an officer has reason to believe the noncitizen is present in violation of the relevant law or regulation and is likely to escape before a warrant can be obtained. Following Zurita Navarro and Matthews Gomes Da Silva Julio, the court held that the detention was unlawful and ordered immediate release.
The operative judgment granted the habeas petition, ordered the California City Immigration Processing Center to release Valle Castillo immediately, and barred re-detention for any purpose absent exigent circumstances unless he receives notice and a pre-detention hearing before an immigration judge. At that hearing, the burden must be set according to § 1226(a) and its implementing regulations. The temporary-restraining-order motion was denied as moot because the habeas ruling supplied the requested release. The clerk was directed to serve the order on the facility, enter judgment for Valle Castillo, and close the case.
Key Takeaways
- The government conceded that 8 U.S.C. § 1226(a) governed, but the record contained no evidence that ICE arrested Valle Castillo with the required warrant.
- The respondent did not invoke the statutory warrantless-arrest exception, leaving no argued basis for excusing the missing warrant.
- The court waived administrative exhaustion to prevent additional irreparable harm and delay in vindicating the petitioner’s rights.
- Relief included both immediate release and protection against re-detention without notice and a pre-detention immigration-judge hearing, absent exigent circumstances.
- The temporary-restraining-order motion became moot once the court granted habeas relief, and judgment was entered for the petitioner.
Why It Matters
The order applies the court’s earlier § 1226(a) decisions to a conceded statutory framework and an undeveloped warrant record. It did not merely direct further immigration-custody proceedings: it found the existing detention unlawful and required immediate release. The respondent’s constitutional defense of the statutory procedures did not overcome the absence of evidence showing compliance with the warrant requirement or an argument establishing the exception.
The re-detention restriction also defines the practical scope of the judgment. Any future detention, absent exigent circumstances, must follow notice and a pre-detention hearing before an immigration judge, with the burden allocated under § 1226(a) and its regulations. The order resolved the petition on the merits rather than leaving exhaustion or the temporary-motion briefing as obstacles to a final disposition, and it closed the case with judgment for the petitioner.