Summary
The United States District Court for the Western District of Louisiana denied Muhammad Ali’s motion for a temporary restraining order and preliminary injunction. The court held that it lacked jurisdiction under 8 U.S.C. § 1252(g) to stay removal and declined to order immediate release or prohibit a potential transfer because those requests were either premature or unsupported by a sufficient showing of irreparable injury.
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Practice areas
Questions Presented
- Whether the district court had jurisdiction to stay Petitioner's removal while his habeas petition was pending.
- Whether the court could grant immediate release through preliminary injunctive relief when that relief would effectively resolve the merits of the pending habeas petition.
- Whether Petitioner established entitlement to an injunction prohibiting his transfer to another detention facility.
- Whether Petitioner satisfied the requirements for a temporary restraining order or preliminary injunction.
Holdings
- The district court lacked jurisdiction to grant Petitioner's request for a stay of removal because the request challenged a removal order and was directly connected to the Attorney General's execution of a removal order.
- The court declined to grant immediate release because doing so would effectively decide the merits of the habeas petition before development of a complete record.
- Petitioner was not entitled to an injunction prohibiting his transfer because he failed to show a likelihood that he would be transferred and relied on speculation and conclusory allegations of irreparable injury.
- The motion for a temporary restraining order and preliminary injunction was denied because Petitioner did not establish the requirements for extraordinary injunctive relief.
Key quotations
“An applicant for a Temporary Restraining Order must demonstrate each of the following: (1) a substantial likelihood his cause will succeed on the merits, (2) a substantial threat of irreparable injury if the injunction is not granted, (3) the threatened injury outweighs the threatened harm the injunction may do to the opposing party, and (4) granting the injunction will not disserve the public interest.”
“Thus, this Court is without jurisdiction to grant Petitioner’s request for stay of removal.”
Factual background
Petitioner Muhammad Ali entered the United States without inspection and was detained in September 2024. An immigration judge granted him withholding of removal in March 2025, but he remained in custody at the River Correctional Center in Ferriday, Louisiana. In his pending habeas action, he sought immediate release, a stay of removal, and an order preventing his transfer outside the court's jurisdiction.
Procedural history
Petitioner entered the United States without inspection and was detained in September 2024. An immigration judge granted him withholding of removal in March 2025, but he remained detained. While his habeas petition was pending, he moved for emergency injunctive relief. The district court denied the motion.