Summary
The United States District Court for the Western District of Texas granted Jennifher Pahola Umanzor Maldonado’s petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court held that the respondents could not detain her under 8 U.S.C. § 1225(b) under the circumstances presented and ordered her release under appropriate conditions. The court also addressed its jurisdiction to preserve existing conditions pending resolution of the habeas petition and dissolved the stay upon entry and closing of the case.
Holdings
- The district court had jurisdiction to consider the arguments presented in the § 2241 habeas petition.
- Under the facts presented, Respondents could not detain Petitioner under either 8 U.S.C. § 1225(b)(1) or § 1225(b)(2), and her detention was unlawful.
- The court had inherent power to issue a stay preserving existing conditions while determining its authority to grant injunctive relief, although the stay would be dissolved upon entry of the order and closing of the case.
- Fees under the Equal Access to Justice Act, 28 U.S.C. § 2412, were not available in this habeas corpus proceeding.
- Maldonado Bautista v. Santacruz did not preclude granting habeas relief at that time.
Questions Presented
- Whether the district court had jurisdiction to consider the § 2241 habeas petition challenging Petitioner's immigration detention.
- Whether Respondents could detain Petitioner under 8 U.S.C. § 1225(b)(1) or § 1225(b)(2) under the facts presented.
- Whether the court's service order and stay preserving Petitioner's existing conditions exceeded the court's jurisdiction.
- Whether the Equal Access to Justice Act permits an award of fees in this habeas proceeding.
- Whether Maldonado Bautista v. Santacruz precluded habeas relief.
Disposition
writ_granted
Cases Cited (14)
- Diaz Perez v. Thompson, No. 5:25-CV-1664-JKP, 2025 WL 3654333 (W.D. Tex. Dec. 15, 2025)(relied on)
- Davila Mercado v. Lyons, No. 5:25-CV-1623-JKP, 2025 WL 3654268 (W.D. Tex. Dec. 11, 2025)(relied on)
- Orellana v. U.S. Dep’t of Homeland Sec., No. 5:25-CV-1028-JKP, 2025 WL 3471569 (W.D. Tex. Nov. 24, 2025)(relied on)
- Gonzalez v. Ortega, No. 5:25-CV-1156-JKP, 2025 WL 3471571 (W.D. Tex. Nov. 24, 2025)(relied on)
- Trujillo v. Noem, No. 5:25-CV-1266-JKP, 2025 WL 3471572 (W.D. Tex. Nov. 24, 2025)(relied on)
- Granados v. Noem, No. SA-25-CA-01464-XR, 2025 WL 3296314 (W.D. Tex. Nov. 26, 2025)(relied on)
- Tinoco Pineda v. Noem, No. SA-25-CA-01518-XR, 2025 WL(relied on)
- Reyes-Lopez v. Bondi, No. 5:25-CV-1800-JKP, 2026 WL 94653, at *1 (W.D. Tex. Jan. 6, 2026)(followed)
- Montilla De Diaz v. Lyons, No. 5:25-CV-1809-JKP, 2026 WL 94645, at *1 (W.D. Tex. Jan. 6, 2026)(followed)
- Imran v. Harper, No. 25-30370, 2026 WL 93131, at *1 (5th Cir. Jan. 13, 2026)(distinguished)
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