Unreported / Non-Citable
Background
Arsen Yeghiazaryan, a noncitizen held in immigration detention, petitioned for habeas relief in the U.S. District Court for the Central District of California against the Warden of Desert View Annex Desert. A United States Magistrate Judge issued a Report and Recommendation concluding that the respondent failed to provide Yeghiazaryan the process he was due, violating applicable regulations and his due process rights. The Report recommended granting the petition, ordering his release, reinstating his prior conditions of supervision, returning confiscated property, and limiting re-detention absent a pre-detention hearing.
The respondent filed objections on October 29, 2026, one day after the shortened deadline of October 28 set by the Report given the nature of the relief at issue. Yeghiazaryan asked the court to enforce the deadline and filed a supplemental memorandum, which the court construed as a response to the objections. The respondent's objections did not dispute the underlying due process violation but narrowly argued that the recommended restriction on re-detention was duplicative of regulations the government must already follow.
The Court’s Holding
District Judge Michael W. Fitzgerald declined to strike the untimely objections, citing the strong preference for disposing of matters on the merits, and conducted a de novo review of the portions of the Report to which the objections were directed. The court overruled the objections, reasoning that it would not reject any aspect of the Report that merely restates regulatory requirements the government is already obligated to follow, and pointing to authority confirming that even after habeas relief is granted the government must comply with its own regulations before revoking an order of supervision and has no legitimate interest in re-detaining noncitizens without a hearing already required by law.
The court accepted the Report in full, granted the petition, and directed entry of judgment ordering Yeghiazaryan's immediate release from custody, reinstatement of his previous conditions of supervision, and return of all property confiscated during his arrest and processing into detention. The judgment further bars the respondent and its officers, agents, employees, attorneys, and others acting in concert with it from re-detaining Yeghiazaryan without notice and an individualized pre-detention hearing before a neutral arbiter establishing that detention is lawful and warranted, and from removing him to any country without appropriate notice and an opportunity to be heard, including the chance to assert a torture-based or fear-based objection.
Key Takeaways
- A district court may decline to strike untimely objections to a magistrate judge's report and instead conduct de novo review, reflecting the strong preference for resolving matters on the merits.
- When the government does not refute a finding that it violated a detainee's due process rights, narrow objections to the scope of relief are unlikely to succeed.
- An injunction that restates existing regulatory obligations is not improper merely because it duplicates rules the government must already follow.
- Habeas relief in immigration detention cases can include immediate release, reinstatement of supervision conditions, return of confiscated property, and forward-looking limits on re-detention and removal.
- Pre-detention hearing requirements can be framed around whether the detainee violated a supervision term or whether removal from the United States is significantly likely in the reasonably foreseeable future.
Why It Matters
The order underscores that federal courts will enforce due process protections in immigration detention even where the government concedes the underlying violation, and that remedial orders may prospectively constrain re-detention and removal to prevent repeat violations. It also illustrates the practical interplay between magistrate recommendations and district court review, showing that procedural missteps like a late objection will not necessarily defeat substantive relief.
By requiring an individualized hearing before a neutral arbiter and preserving torture-based and fear-based objections before any removal, the decision reinforces procedural safeguards for noncitizens on orders of supervision and signals that courts will not treat compliance with existing regulations as a reason to withhold injunctive protection.