Abdullah Ahmad Jumadar v. Dora Castro, et al.

Summary

The United States District Court for the District of New Mexico granted the Government’s motion to dismiss and denied without prejudice Abdullah Ahmad Jumadar’s habeas petition under 28 U.S.C. § 2241. The court held that his detention following the October 9, 2025 administratively final removal order had lasted less than the six-month presumptively reasonable period recognized in Zadvydas v. Davis. The court declined to apply the Zadvydas period from the date of his initial arrest.

Holdings

1. Jumadar had not been detained for six months after his removal order became administratively final, so he did not establish a Zadvydas claim and was not entitled to habeas relief.
2. The Zadvydas six-month period begins when the removal order becomes administratively final, not when the noncitizen is initially arrested.
3. The petition was properly denied without prejudice to refiling after the presumptively reasonable six-month period expires.

Questions Presented

1. Whether Jumadar's detention violated due process under Zadvydas v. Davis because the presumptively reasonable six-month period had expired.
2. Whether the Zadvydas detention period began when Jumadar was originally arrested or when his removal order became administratively final.
3. Whether Jumadar was entitled to habeas relief, including release, based on his challenge to detention and his final removal order.

Disposition

dismissed