Summary
The United States District Court for the Western District of Missouri granted Santo Alberto Bumbila Iza’s petition for a writ of habeas corpus after determining that immigration officials revoked his prior release and detained him without demonstrating changed circumstances or providing adequate procedural protections. The court ordered his immediate release subject to the conditions of his prior release and enjoined respondents from transferring him outside the court’s jurisdiction before complying with the order. The court also held that Bumbila Iza may seek attorneys’ fees and costs under the Equal Access to Justice Act.
Court
United States District Court for the Western District of Missouri, Southern Division
Jurisdiction
United States District Court for the Western District of Missouri, Southern Division
Decision date
January 8, 2026
Docket number
6:25-cv-3392-MDH
Disposition
writ_granted
Questions Presented
- Whether 8 U.S.C. §§ 1252(e)(3), 1252(g), or 1252(b)(9) deprived the district court of jurisdiction over Petitioner's § 2241 challenge to his allegedly unlawful detention.
- Whether DHS violated procedural due process by revoking Petitioner's prior release and detaining him without notice, a hearing, or an individualized legal justification based on changed circumstances.
- Whether temporary injunctive relief was appropriate to prevent Respondents from relocating Petitioner outside the court's jurisdiction before complying with the habeas order.
- Whether Petitioner could pursue attorneys' fees and costs under the Equal Access to Justice Act.
Holdings
- Sections 1252(e)(3), 1252(g), and 1252(b)(9) did not deprive the district court of jurisdiction over Petitioner's collateral challenge to his allegedly unlawful detention and revocation of prior release.
- DHS violated Petitioner's procedural due process rights by revoking his prior release and detaining him without notice, an opportunity to be heard, or an individualized legal justification based on changed circumstances.
- A temporary restraining order was appropriate to prevent Respondents from relocating Petitioner outside the court's jurisdiction before compliance with the habeas order.
Court Document
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