Alberto Garcia, et al. v. Cammilla Wamsley, et al.

District Court, W.D. Washington·Decided March 19, 2026·No. 2:25-cv-01980·Unknown

Opinion

1 2 3

4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 ALBERTO GARCIA, et al., Case No. 2:25-cv-01980-TMC 8 Petitioner, ORDER GRANTING IN PART MOTION 9 FOR ATTORNEY’S FEES v. 10 CAMMILLA WAMSLEY, et al., 11 Respondent. 12 13 14 I. INTRODUCTION 15 Petitioners Alberto Garcia, Fernando Rangel-Saucedo, and Ismael Ortiz Montoya 16 obtained habeas relief when this Court held they had been unlawfully subject to mandatory 17 immigration detention without an opportunity for bond. Dkt. 11. After securing the writ, all three 18 petitioners were released from custody because they were otherwise bond eligible. Dkt. 23 ¶¶ 6– 19 8.Their habeas petition was the first group petition brought to enforce the declaratory judgment 20 entered in Rodriguez Vazquez v. Bostock, 802 F. Supp. 3d 1297, 1336 (W.D. Wash. 2025). All 21 three petitioners were class members, and they were represented by class counsel from the 22 Northwest Immigrant Rights Project (NWIRP), who have since filed group petitions on a weekly 23 basis to obtain efficient relief for as many class members as possible. See, e.g., Tiul Caal v. 24 Hernandez, No. 2:26-cv-00850-TMC, 2026 WL 754035 (W.D. Wash. Mar. 17, 2026); Su v. 1 Hernandez, No. 2:26-cv-00765-TMC, 2026 WL 675287 (W.D. Wash. Mar. 10, 2026); Flores- 2 Velazquez v. Hermosillo, No. 2:26-cv-00600-TMC, 2026 WL 523283 (W.D. Wash. Feb. 25, 3 2026).

4 Petitioners now move for an award of attorney’s fees under the Equal Access to Justice 5 Act (EAJA), 28 U.S.C. § 2142(d). Dkt. 13. They ask for fees at market rates rather than statutory 6 EAJA rates given the complexity of both the underlying litigation and the enforcement process 7 resulting from Respondents’ failure to comply with the Rodriguez Vazquez declaratory judgment. 8 Id. at 2–3. Respondents agree that Petitioners were the prevailing parties. But they argue that fees 9 should be denied because their legal positions are substantially justified, and alternatively if fees 10 are awarded, they should be limited to the statutory rates. See Dkt. 22 at 1–2. 11 For reasons similar to those explained in M.M. v. Hermosillo, No. 2:25-cv-02074-TMC, 12 2026 WL 252076 (W.D. Wash. Jan. 30, 2026), and Rodriguez Vazquez v. Hermosillo, --- F.

13 Supp. 3d ---, 2026 WL 102461 (W.D. Wash. Jan. 14, 2026), the Court concludes that Petitioners 14 are entitled to attorney’s fees under the EAJA. When Petitioners were denied bond in 15 immigration court, the immigration judge (IJ) concluded that each would be entitled to bond if 16 the IJ had jurisdiction to grant it. The IJ thus entered an “alternative” order setting a bond amount 17 if jurisdiction existed. This Article III Court then entered a declaratory judgment that the IJs did 18 have jurisdiction to grant bond because applying mandatory detention to noncitizens such as 19 Petitioners violates the law. Rodriguez Vazquez v. Bostock, 802 F. Supp. 3d at 1336. But rather 20 than follow that judgment, the government kept Petitioners detained. 21 Because the Rodriguez Vazquez declaratory judgment was binding on the parties to the 22 case, and the defendants did not seek a stay of the judgment pending appeal, there was no

23 reasonable basis for the government to ignore the judgment and force class members to file 24 habeas petitions as their only means of seeking relief from unlawful detention. Respondents’ 1 position was therefore not substantially justified, and their new arguments in defense of these 2 decisions remain unpersuasive. 3 Petitioners also meet the standard for receiving attorney’s fees at market rates; however,

4 the Court will award fees based on evidence of the prevailing market rates in this district rather 5 than the requested Fitzpatrick Matrix. Because Petitioners are entitled to fees under the EAJA, 6 the Court does not address their arguments that fees would also be warranted as a sanction for 7 bad-faith litigation conduct. 8 II. LEGAL STANDARD “The EAJA provides . . . that in an action brought by or against the United States, a court 9 must award fees and expenses to a prevailing non-government party ‘unless the court finds that 10 the position of the United States was substantially justified or that special circumstances make an 11 award unjust.’” Medina Tovar v. Zuchowski, 41 F.4th 1085, 1089 (9th Cir. 2022) (quoting 12 28 U.S.C. § 2412(d)(1)(A)). “For the court to award attorney’s fees and costs pursuant to the 13 EAJA, it must be shown that (1) the plaintiff is the prevailing party; (2) the government has not 14 met its burden of showing that its positions were substantially justified or that special 15 circumstances make an award unjust; and (3) the requested attorney’s fees and costs are 16 reasonable.” Perez-Arellano v. Smith, 279 F.3d 791, 793 (9th Cir. 2002). 17 “It is the government’s burden to show that its position was substantially justified.” 18 Medina Tovar, 41 F.4th at 1089. Substantially justified means “justified to a degree that could 19 satisfy a reasonable person.” Meier v. Colvin, 727 F.3d 867, 870 (9th Cir. 2013) (quoting Pierce 20 v. Underwood, 487 U.S. 552, 565 (1988)). “Put differently, the government’s position must have 21 a ‘reasonable basis both in law and fact.’” Id. (quoting Pierce, 487 U.S. at 565). The court 22 examines “both the government’s litigation position and the underlying agency action giving rise 23 24 1 to the civil action.” Id. Whether the government’s position was substantially justified is a matter 2 of discretion for the district court. Id. at 869. 3 With respect to the reasonableness of fees and costs, EAJA provides that “attorney fees

4 shall not be awarded in excess of $125 per hour unless the court determines that an increase in 5 the cost of living or a special factor, such as the limited availability of qualified attorneys for the 6 proceedings involved, justifies a higher fee.” 28 U.S.C. § 2412(d)(2)(A). A court may award 7 market rates based on the limited availability of qualified attorneys when the attorneys possess 8 (1) “distinctive knowledge and specialized skill” that was (2) “needful to the litigation in 9 question” and (3) “not available elsewhere at the statutory rate.” Nadarajah v. Holder, 569 F.3d 10 906, 912 (9th Cir. 2009) (citation modified). 11 Under Federal Rule of Civil Procedure 54(d)(2)(C), when ruling on a motion for 12 attorney’s fees, the Court “must find the facts and state its conclusions of law as provided in Rule

13 52(a),” meaning “the court must find the facts specially and state its conclusions of law 14 separately.” Fed. R. Civ. P. 52(a)(1), 54(d)(2)(C). 15 III. FINDINGS OF FACT 1. Petitioner Garcia entered the United States over thirty years ago. Dkt. 1 ¶ 4. He 16 had no criminal history and worked as a painter. Dkt. 3-3 at 3. Immigrations & 17 Customs Enforcement (ICE) officers arrested him on August 11, 2025 while they 18 were looking for someone else, and he was detained at the Northwest ICE 19 Processing Center (NWIPC) in Tacoma, Washington. Id. at 3–4. 20 2.

Free access — add to your briefcase to read the full text and ask questions with AI

Alberto Garcia, et al. v. Cammilla Wamsley, et al., (W.D. Wash. 2026).

Alberto Garcia, et al. v. Cammilla Wamsley, et al. (Alberto Garcia, et al. v. Cammilla Wamsley, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Maness v. Meyers
419 U.S. 449 (Supreme Court, 1975)
United States v. Mendoza
464 U.S. 154 (Supreme Court, 1984)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Devlin v. Scardelletti
536 U.S. 1 (Supreme Court, 2002)
Perez-Arellano v. Smith
279 F.3d 791 (Ninth Circuit, 2002)
Jeffrey Meier v. Carolyn W. Colvin
727 F.3d 867 (Ninth Circuit, 2013)
Maria Medina Tovar v. Laura Zuchowski
41 F.4th 1085 (Ninth Circuit, 2022)
Camreta v. Greene
179 L. Ed. 2d 1118 (Supreme Court, 2011)
City & County of San Francisco v. Merrick Garland
42 F.4th 1078 (Ninth Circuit, 2022)
Rincon Band of Mission Indians v. Harris
618 F.2d 569 (Ninth Circuit, 1980)
United Steelworkers v. Phelps Dodge Corp.
896 F.2d 403 (Ninth Circuit, 1990)
United Aeronautical Corp. v. Usaf
80 F.4th 1017 (Ninth Circuit, 2023)
Yajure Hurtado
29 I. & N. Dec. 216 (Board of Immigration Appeals, 2025)