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

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

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

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

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

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

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

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

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