J.G.G. v. Trump

Summary

This memorandum opinion addresses habeas jurisdiction, constructive custody, class certification, mootness, and due-process claims arising from the removal of Venezuelan detainees from the United States to El Salvador under the Alien Enemies Act. The court concludes that the United States maintained constructive custody over the detainees, certifies a class of individuals removed on March 15, and determines that the class was denied constitutionally required process. The court orders the government to facilitate the class members’ ability to obtain a hearing.

Holdings

1. The Court had habeas jurisdiction because Plaintiffs were in constructive custody of the United States when they filed their habeas claims. El Salvador acted as the United States' agent in detaining Plaintiffs at the United States' behest, and the United States retained sufficient control over their detention and release.
2. Plaintiffs' claims were not moot after their release from CECOT and transfer to Venezuela because they continued to suffer concrete, redressable collateral consequences from their designations and removal.
3. The All Writs Act authorizes a court with habeas jurisdiction to use a class-like representative procedure to aggregate habeas claims when doing so is necessary or appropriate to protect and administer the court's jurisdiction.
4. The Court certified a class consisting of all noncitizens removed from U.S. custody and transferred to CECOT in El Salvador on March 15 and 16, 2025, solely pursuant to the Alien Enemies Act Proclamation.
5. The CECOT class was denied due process because class members received no meaningful notice of their AEA designations and no opportunity to challenge those designations before removal.
6. Habeas relief is not limited to release from physical custody and may require the Government to facilitate Plaintiffs' return to the United States or otherwise provide a meaningful opportunity to challenge their designations and the Proclamation.

Questions Presented

1. Whether the Court had habeas jurisdiction under 28 U.S.C. § 2241 over Plaintiffs who were physically detained in El Salvador when they filed their Amended Complaint.
2. Whether Plaintiffs' claims became moot after their release from CECOT and transfer to Venezuela.
3. Whether habeas claims may be aggregated through a class-like procedure under the All Writs Act and whether the proposed CECOT class satisfied the relevant Rule 23 requirements.
4. Whether the Government violated the class members' due-process rights by removing them under the Alien Enemies Act without meaningful notice or an opportunity to challenge their designations.
5. Whether habeas relief may require the Government to facilitate Plaintiffs' return to the United States or otherwise provide a meaningful hearing.

Disposition

other