Unreported / Non-Citable
Background
Jobanjeet Singh filed this petition for a writ of habeas corpus under 28 U.S.C. § 2241 on September 17, 2026. The court identified it as his third petition in the district challenging his immigration detention. His first petition, filed with counsel on January 9, 2026, was granted after briefing on January 23, 2026. The court ordered that Singh be granted a bond hearing before an Immigration Judge within 14 days, after which the Clerk entered judgment and closed that case.
Singh later moved to enforce the first judgment. The court denied that motion after hearing from the Government, finding that the Government had complied with the earlier bond-hearing order and that Singh had failed to exhaust his administrative remedies. The court reasoned that an appeal to the Board of Immigration Appeals was a necessary prerequisite before the court could consider any error by the Immigration Judge. Singh's amended enforcement motion, filed through new counsel, was denied on July 27, 2026, because it improperly sought reconsideration of the prior ruling.
He then filed a second petition without counsel, which the court dismissed on August 18, 2026, as repetitive or duplicative because it provided no new information or grounds for relief beyond the first petition and the two enforcement motions, and because administrative remedies remained unexhausted. The present order addresses the third petition filed on September 17, 2026.
The Court’s Holding
Having reviewed the new petition, the court found it subject to dismissal for the same reasons stated in its disposition of the second petition. It therefore denied the petition rather than ordering further merits proceedings. The court also denied Singh's motion to appoint counsel as moot. Its reasoning incorporated the earlier determination that the filings supplied no new information or grounds for relief beyond the first petition and the two enforcement motions, together with the finding that administrative remedies remained unexhausted.
The operative judgment direction was a dismissal without prejudice, not an adjudication that permanently barred Singh from seeking relief after satisfying the necessary prerequisites. The Clerk of Court was directed to enter a judgment dismissing the action without prejudice and close the case file. The order did not grant a new bond hearing, appoint counsel, or reconsider the earlier enforcement rulings. Its immediate result was to end this third action while leaving the dismissal without prejudice.
Key Takeaways
- A prior successful habeas petition resulting in a bond-hearing order did not permit Singh to bypass administrative review of the Immigration Judge's subsequent decision.
- The court treated an appeal to the Board of Immigration Appeals as a necessary prerequisite before it could consider alleged Immigration Judge error in this procedural sequence.
- The third petition was denied because it suffered from the same repetition and exhaustion defects identified in the second petition.
- Denial of the petition made the pending motion to appoint counsel moot.
- The action was dismissed without prejudice, so the order should not be described as a with-prejudice merits judgment against detention relief.
Why It Matters
The order illustrates the distinction between obtaining judicial relief that secures a bond hearing and obtaining federal-court review of the conduct or result of that hearing. In this case, the court required administrative exhaustion through the Board of Immigration Appeals before considering alleged Immigration Judge error. It also applied summary-dismissal principles to a renewed filing that offered no new information or grounds beyond earlier petitions and enforcement motions.
The decision is brief and rests substantially on the court's earlier rulings rather than developing a new legal standard. Its practical importance is case-specific: repeated filings and renewed enforcement requests did not substitute for the required administrative appeal, while the without-prejudice disposition preserved the distinction between this dismissal and a permanent adverse merits determination.