Enwonwu v. Joyce

United States District Court, District of Maine · February 24, 2025 · No. 2:24-cv-00320-NT

Summary

This federal district court order resolves a pro se petition for writs of habeas corpus and mandamus filed by an individual detained by ICE pending removal. The court granted the petitioner's motion to transfer venue from the District of Maine to the Western District of Louisiana, citing his extended detention exceeding six months and his physical relocation to a Louisiana facility. As a result, the magistrate judge's prior recommended decisions on the petition are rendered moot.

Court
United States District Court, District of Maine
Writing for the Court
Nancy Torresen
Jurisdiction
United States District Court for the District of Maine
Decision date
February 24, 2025
Docket number
2:24-cv-00320-NT
Procedural posture
Petition for writ of habeas corpus; magistrate recommended dismissal; district court considered motion to change venue.
Precedential value
nonprecedential
Disposition
other

Topics

venuecivil procedureimmigration

Practice areas

civil procedureimmigration

Questions Presented

  1. Whether the district court may transfer venue under 28 U.S.C. §1404(a) given the plaintiff's custody status and convenience considerations.

Holdings

  1. The motion to change venue is granted and the case is transferred to the U.S. District Court for the Western District of Louisiana.

Key quotations

Section 1404(a) is intended to place discretion in the district court to adjudicate motions for transfer according to an individualized, case-by-case consideration of convenience and fairness.

Factual background

Francis Enwonwu was in ICE custody for more than six months, having been transferred from the Cumberland County Sheriff’s Office in Maine to an ICE detention facility in Louisiana in December 2024.

Procedural history

The magistrate judge recommended dismissal of the petition. The district court granted the plaintiff's motion to change venue and ordered transfer to the Western District of Louisiana.

Remand instructions

Transfer the case, including the pending petition, to the United States District Court for the Western District of Louisiana.

Court Document

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