Unreported / Non-Citable
Background
Petitioner William Alfredo Be Caamal, a federal immigration detainee, filed a petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241 on June 19, 2026, along with a motion for a temporary restraining order (ECF Nos. 1, 2). The petition challenges his mandatory detention under immigration law. On October 19, 2026, the assigned district judge denied the motion for a temporary restraining order and referred the matter to Magistrate Judge Stanley A. Boone for further proceedings (ECF No. 18).
The referral to the magistrate judge triggered the need for a structured briefing schedule to adjudicate the habeas petition. The court noted a potentially controlling precedent from this district, S.G. v. Warden of the Golden State Annex Det. Facility, No. 1:26-CV-03322-TLN-JDP, 2026 WL 2475525 (E.D. Cal. Aug. 24, 2026), which held that 8 U.S.C. § 1226(c)(1)(A) does not authorize mandatory detention where the government has failed to administratively charge a noncitizen with inadmissibility by reason of having committed an offense covered by 8 U.S.C. § 1182(a)(2).
The Court’s Holding
Magistrate Judge Boone ordered Respondents to file a response to the petition within 21 days of service of the order. The response must address the merits of the petition and specifically argue whether this case is distinguishable from the S.G. precedent regarding the statutory authority for mandatory detention under § 1226(c)(1)(A) absent a proper administrative charge of inadmissibility under § 1182(a)(2).
The court further ordered Respondents to file all relevant portions of Petitioner's Alien File (A-File) and any other documentation relevant to the issues raised in the petition within the same 21-day period. Petitioner is granted leave to file a reply brief within 14 days after Respondents' response is filed. The order establishes the procedural framework for adjudicating the habeas petition but does not rule on the merits of the detention challenge.
Key Takeaways
- The court has established a briefing schedule for a habeas corpus petition challenging mandatory immigration detention under 28 U.S.C. § 2241.
- Respondents must specifically address whether the petitioner's detention is distinguishable from S.G. v. Warden of the Golden State Annex Det. Facility, where the court found § 1226(c)(1)(A) inapplicable without a proper administrative charge under § 1182(a)(2).
- Respondents are required to produce the petitioner's complete Alien File and all relevant documentation within 21 days.
- The magistrate judge is managing the case following referral from the district judge, who previously denied a temporary restraining order.
- The order is purely procedural and does not reach the merits of the habeas petition.
Why It Matters
This order reflects the Eastern District of California's ongoing scrutiny of mandatory immigration detention under § 1226(c) when the government has not properly charged the noncitizen with inadmissibility under § 1182(a)(2). The citation to S.G. signals that the court views the administrative charging requirement as a potential threshold issue in such cases. The directive to produce the A-File ensures the record will be complete for evaluating whether the statutory prerequisites for mandatory detention were met.
The case remains at an early procedural stage. The district judge's prior denial of the TRO suggests the court did not find immediate irreparable harm warranting emergency relief, but the referral for full briefing indicates the legal questions surrounding the detention authority are substantial enough to warrant full adjudication. The outcome may contribute to the developing body of case law in this district on the interplay between § 1226(c) and § 1182(a)(2) charging requirements.