Unreported / Non-Citable
Background
Petitioner Marvin A.M. filed a petition for writ of habeas corpus under 28 U.S.C. § 2241 challenging his immigration detention. The case was assigned to the Eastern District of California, and the magistrate judge issued findings and recommendations on October 26, 2026. Those findings recommended that the petition be granted and that respondents be directed to immediately release petitioner. Respondents filed timely objections on October 29, 2026, contesting the recommended disposition.
The district court conducted a de novo review of the entire file, including the objections, as required by 28 U.S.C. § 636(b)(1)(C). The court noted that petitioner was released on humanitarian parole in 2024 and has no criminal history whatsoever. The court also referenced its recent decision in Charles v. Warden, California City Detention Facility, where it explained why respondents' objections — premised on Padilla v. U.S. Immigration & Customs Enforcement, Shaughnessy v. United States ex rel. Mezei, and Barrera-Echavarria v. Rison — were not persuasive. The court agreed with the magistrate judge that petitioner is entitled to habeas relief on his due process claim and falls into the category of individuals for whom immediate release is appropriate.
The Court’s Holding
The district court concluded that the magistrate judge's findings and recommendations were supported by the record and proper analysis. The court agreed that petitioner is entitled to habeas relief on his due process claim and falls into the category of individuals for whom immediate release is appropriate. The court adopted the findings and recommendations in full, granted the petition for writ of habeas corpus, and ordered respondents to immediately release petitioner from custody.
The court issued five specific orders: (1) the findings and recommendations issued on October 26, 2026 were adopted in full; (2) the petition for writ of habeas corpus was granted; (3) respondents were ordered to immediately release petitioner from their custody; (4) the Clerk of Court was directed to serve the Central Valley Annex with a copy of the order; and (5) the Clerk of Court was directed to close the case and terminate all pending motions as moot.
Key Takeaways
- The district court conducted a de novo review under 28 U.S.C. § 636(b)(1)(C) and adopted the magistrate judge's findings and recommendations in full.
- The court granted the habeas petition and ordered immediate release of the petitioner from immigration detention.
- The court rejected respondents' objections based on Padilla, Shaughnessy, and Barrera-Echavarria as unpersuasive, consistent with its recent ruling in Charles v. Warden.
- Petitioner's humanitarian parole release in 2024 and lack of criminal history supported the determination that immediate release was appropriate.
- The case was closed and all pending motions terminated as moot.
Why It Matters
This order reinforces due process protections for immigration detainees with no criminal history who have been granted humanitarian parole, confirming that continued detention in such circumstances warrants habeas relief. The decision aligns with the court's recent precedent in Charles v. Warden and contributes to the developing jurisprudence on the limits of immigration detention authority.
The order also demonstrates the district court's application of de novo review under 28 U.S.C. § 636(b)(1)(C) in the habeas context, where the court independently evaluated the magistrate judge's findings and the respondents' objections before adopting the recommendation for immediate release.