Abbas Qaisar v. Warden, et al.

CourtDistrict Court, E.D. California
DecidedApril 23, 2026
Docket2:26-cv-00425
StatusUnknown

This text of Abbas Qaisar v. Warden, et al. (Abbas Qaisar v. Warden, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abbas Qaisar v. Warden, et al., (E.D. Cal. 2026).

Opinion

7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9

10 ABBAS QAISAR, Case No. 2:26-cv-00425-KES-SAB-HC

11 Petitioner, FINDINGS AND RECOMMENDATION TO GRANT FIRST AMENDED PETITION FOR 12 v. WRIT OF HABEAS CORPUS, DENY RESPONDENTS’ MOTION TO DISMISS, 13 WARDEN, et al., AND DIRECT RESPONDENTS TO PROVIDE PETITIONER WITH BOND 14 Respondents. HEARING BEFORE IMMIGRATION JUDGE 15 (ECF Nos. 15, 18) 16 17 Petitioner, represented by counsel, is an immigration detainee proceeding with a petition 18 for writ of habeas corpus pursuant to 28 U.S.C. § 2241. 19 I. 20 BACKGROUND 21 Petitioner is a citizen of Pakistan who entered the United States on January 7, 2025, was 22 encountered by the Department of Homeland Security (“DHS”), charged as an alien present in 23 the United States who has not been admitted or paroled, and detained. (ECF No. 15 at 4; ECF 24 No. 15-1 at 4.1) Petitioner is currently detained at the California City Detention Facility. (ECF 25 No. 15 at 4.) On January 5, 2026, an immigration judge denied Petitioner’s claims for relief, and 26 on January 28, 2026, an appeal was filed with the Board of Immigration Appeals (“BIA”). That 27 appeal remains pending. (ECF No. 15 at 24.) 1 On February 13, 2026, Petitioner filed a petition for writ of habeas corpus and a motion 2 for temporary restraining order. (ECF Nos. 1, 2.) On February 19, 2026, the Court granted 3 Petitioner’s motion to appoint counsel. (ECF No. 9.) On March 11, 2026, Petitioner filed a first 4 amended petition (“FAP”) challenging his prolonged detention on due process grounds. (ECF 5 No. 15.) On March 27, 2026, Respondents filed a motion to dismiss. (ECF No. 18.) To date, no 6 response to the motion to dismiss has been filed, and the time for doing so has passed. 7 II. 8 DISCUSSION 9 A. Overview of Caselaw Regarding Immigration Detention Statutes 10 An intricate statutory scheme governs the detention of noncitizens during removal 11 proceedings and after a final removal order is issued. “Where an alien falls within this statutory 12 scheme can affect whether his detention is mandatory or discretionary, as well as the kind of 13 review process available to him if he wishes to contest the necessity of his detention.” Prieto- 14 Romero v. Clark, 534 F.3d 1053, 1057 (9th Cir. 2008). 15 “Four statutes grant the Government authority to detain noncitizens who have been 16 placed in removal proceedings: 8 U.S.C. §§ 1225(b) (‘Section 1225(b)’), 1226(a) (‘Subsection 17 A’), 1226(c) (‘Subsection C’), and 1231(a) (‘Section 1231(a)’).” Avilez v. Garland, 69 F.4th 18 525, 529 (9th Cir. 2023). “Subsection A is the default detention statute for noncitizens in 19 removal proceedings and applies to noncitizens ‘[e]xcept as provided in [Subsection C].’” 20 Avilez, 69 F.4th at 529 (alteration in original) (quoting 8 U.S.C. § 1226(a)). “[D]etention under 21 Subsection A is discretionary” and “provides for release on bond or conditional parole.” Id. 22 “Subsection C provides for the detention of ‘criminal aliens’ and states that ‘[t]he Attorney 23 General shall take into custody any alien who’ is deportable or inadmissible based on a 24 qualifying, enumerated offense.” Avilez, 69 F.4th at 530 (alteration in original) (quoting 8 25 U.S.C. § 1226(c)). “[D]etention under Subsection C is mandatory,” and “[r]elease under 26 Subsection C is limited to certain witness protection purposes.” Id. “Section 1231(a) applies to 27 detention after the entry of a final order of removal” and “governs detention during a ninety-day 1 “[I]n a series of decisions since 2001, ‘the Supreme Court and [the Ninth Circuit] have 2 grappled in piece-meal fashion with whether the various detention statutes may authorize 3 indefinite or prolonged detention of detainees and, if so, may do so without providing a bond 4 hearing.’” Rodriguez v. Robbins (Rodriguez II), 715 F.3d 1127, 1134 (9th Cir. 2013) (quoting 5 Rodriguez v. Hayes (Rodriguez I), 591 F.3d 1105, 1114 (9th Cir. 2010)). In Zadvydas v. Davis, 6 533 U.S. 678 (2001), two noncitizens, who had been ordered removed but whose removal could 7 not be effectuated due to lack of a repatriation treaty or because their designated countries 8 refused to accept them, challenged their prolonged detention under 8 U.S.C. § 1231(a)(6), which 9 governs detention beyond the ninety-day removal period. Applying the canon of constitutional 10 avoidance because a “statute permitting indefinite detention of an alien would raise a serious 11 constitutional problem,” the Supreme Court “read an implicit limitation into” § 1231(a)(6) and 12 held that the statute “limits an alien’s post-removal-period detention to a period reasonably 13 necessary to bring about that alien’s removal from the United States.” Zadvydas, 533 U.S. at 14 689. Thus, “after a presumptively reasonable six-month period of post-removal period detention, 15 the alien was entitled to release if he successfully demonstrated that there was ‘good reason to 16 believe there is no significant likelihood of removal in the reasonably foreseeable future.’” 17 Prieto-Romero, 534 F.3d at 1062 (quoting Zadvydas, 533 U.S. at 701). 18 In Demore v. Kim, 538 U.S. 510 (2003), the Supreme Court rejected a facial challenge to 19 mandatory detention under 8 U.S.C. § 1226(c). Demore distinguished Zadvydas by emphasizing 20 detention under § 1226(c) has a “definite termination point” and “in the majority of the cases it 21 lasts for less than the 90 days we considered presumptively valid in Zadvydas.” Id. at 529 (noting 22 that “in 85% of the cases in which aliens are detained pursuant to § 1226(c), removal 23 proceedings are completed in an average time of 47 days and a median of 30 days” and “[i]n the 24 remaining 15% of cases, in which the alien appeals the decision of the Immigration Judge to the 25 Board of Immigration Appeals, appeal takes an average of four months, with a median time that 26 is slightly shorter”).2 However, Justice Kennedy’s concurring opinion, which created the 27 2 “Thirteen years after the decision in Demore, the government admitted that the figures it provided to the Court, and 1 majority rejecting the facial challenge to mandatory detention under § 1226(c), specifically noted 2 that “a lawful permanent resident alien such as respondent could be entitled to an individualized 3 determination as to his risk of flight and dangerousness if the continued detention became 4 unreasonable or unjustified.” Demore, 538 U.S. at 532 (Kennedy, J., concurring). 5 In the Rodriguez class action, noncitizens “challenge[d] their prolonged detention 6 pursuant to 8 U.S.C. §§ 1225(b), 1226(a), 1226(c)

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Bluebook (online)
Abbas Qaisar v. Warden, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/abbas-qaisar-v-warden-et-al-caed-2026.