Roberto Maceo Rodriguez v. Warden, Otay Mesa Detention Center

Summary

The United States District Court for the Southern District of California denied Roberto Maceo Rodriguez’s 28 U.S.C. § 2241 habeas petition challenging his immigration detention. The court found that the petition did not sufficiently explain why his August 5, 2025, re-detention was unlawful, while granting leave to amend by January 16, 2026, and directing him to identify respondents by name in their official capacities.

Holdings

1. A habeas petition may be summarily dismissed when it plainly appears that the petitioner is not entitled to relief, and Rodriguez's petition did not meet the low standard requiring only some potential merit because it did not sufficiently explain why his current immigration detention was unlawful.
2. The petition did not allege facts suggesting that Rodriguez's post-removal-order detention had become unconstitutionally prolonged.
3. If Rodriguez files an amended petition challenging his present physical confinement, he must identify the respondent or respondents by name in their official capacities, with the facility warden generally serving as the proper respondent.

Questions Presented

1. Whether the § 2241 petition stated a sufficiently cognizable and potentially meritorious challenge to Rodriguez's immigration detention to avoid summary dismissal.
2. Whether the petition adequately identified a basis for concluding that Rodriguez's re-detention was unlawful or constitutionally prolonged.
3. Whether Rodriguez should be granted leave to amend and instructed to identify the proper habeas respondent.

Disposition

writ_denied