Alvarado Tello v. Barr

CourtDistrict Court, N.D. California
DecidedJuly 29, 2025
Docket3:19-cv-01312
StatusUnknown

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Bluebook
Alvarado Tello v. Barr, (N.D. Cal. 2025).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 FREDY PORFIRIO ALVARADO Case No. 19-cv-01312-CRB TELLO, 9

Plaintiff, ORDER DENYING AMENDED 10 PETITION FOR WRIT OF HABEAS v. CORPUS 11 WILLIAM BARR, et al., 12 Defendants. 13 14 Petitioner Fredy Porfirio Alvarado Tello seeks a writ of habeas corpus challenging a 15 Board of Immigration Appeal decision reversing an immigration judge’s bond 16 determination while his removal proceedings were ongoing.1 His central argument is that 17 the BIA erred by applying a de novo standard of review as to the immigration judge’s 18 finding that he was not a danger to the community. Because the BIA applied the correct 19 standard of review, the Court DENIES Tello’s petition. 20 I. BACKGROUND 21 Tello is a Guatemalan native who has lived in Marin since 1987. Am. Pet. (dkt. 21) 22 ¶ 15. He was lawfully admitted to the United States in 2012 on a U visa. Id. ¶ 17. He has 23 four misdemeanor convictions for driving under the influence from 1993, 2002, 2013, and 24 2018. Id. ¶ 19. 25 1 Petitioner’s counsel has not responded to inquiries as to Petitioner’s current status and, 26 according to the California State Bar, is no longer licensed to practice law in California. See Resps.’ Status Rpt. (dkt. 26) The Court is therefore unaware as to whether Tello has 27 been removed or whether his removal proceedings have been terminated—both of which 1 DHS initially began removal proceedings against Tello in 2010, then terminated 2 those proceedings in 2012 after Tello obtained his U visa. Id. ¶ 20. After Tello’s U visa 3 expired, though, DHS took him back into immigration custody in June 2018 and re- 4 initiated removal proceedings against him. Id. ¶ 21; Mot. to Reconsider (dkt. 14-1) at 5. 5 Tello appeared before an IJ and requested bond, and after a hearing the IJ granted bond. 6 Am. Pet. ¶ 21. DHS then appealed that bond determination to the BIA, which vacated the 7 IJ’s bond holding and ordered DHS to re-detail Tello without bond. Id. ¶ 23; see also Feb. 8 2019 BIA Order (dkt. 21-10). 9 Tello then filed his initial habeas petition seeking to prevent DHS from detaining 10 him. Pet. (dkt. 1). He also moved for a temporary restraining order, which the Court 11 granted on the basis that Tello raised a serious question of law about whether the BIA 12 applied the proper standard of review. Motion for a TRO (dkt. 3); TRO (dkt. 9). DHS 13 then moved for the BIA to reconsider its review of the IJ’s bond holding; the BIA did so, 14 clarifying that it accepted the IJ’s factual findings (and that it would review those only for 15 clear error) but applied a de novo standard of review of the IJ’s determination that Tello 16 was not a danger to the community. Am. Pet. ¶ 26; July 2019 BIA Order (dkt. 21-11). 17 Tello amended his habeas petition to account for the BIA’s clarifying decision. 18 Am. Pet. ¶¶ 1, 5, 26. Tello asserts the same grounds for habeas relief as before—namely, 19 that the BIA wrongly applied a de novo standard of review instead of a clear error test to 20 the IJ’s bond determination. Id. ¶¶ 25–37. 21 II. JURISDICTION 22 District courts have jurisdiction to review noncitizens’ habeas petitions filed under 23 28 U.S.C. § 2241, and they may grant the writ of habeas corpus if the petitioner is “in 24 custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. 25 § 2241(c)(3). In the context of noncitizen habeas petitions, courts have construed “in 26 custody” broadly to include “restraints short of physical confinement.” Rumsfeld v. 27 Padilla, 542 U.S. 426, 437 (2004); see also Nakaranurack v. United States, 68 F.3d 290, 1 which [a noncitizen] is not suffering any actual physical detention.”). All that a petitioner 2 must show is that they are subject to a significant restraint on liberty “not shared by the 3 public generally.” Jones v. Cunningham, 371 U.S. 236, 239–40 (1963). 4 Respondents do not dispute this general principle. Instead, they argue that the 5 Court lacks jurisdiction due to the jurisdiction-stripping provisions of the Immigration and 6 Nationality Act, which preclude judicial review of any “discretionary judgment” exercised 7 by the BIA. 8 U.S.C. § 1226(e). But these provisions do not restrict “habeas jurisdiction 8 over constitutional claims or questions of law.” Singh v. Holder, 683 F.3d 1196, 1202 (9th 9 Cir. 2011), abrogated on other grounds by Rodriguez Diaz v. Garland, 53 F.4th 1189 (9th 10 Cir. 2022); 8 U.S.C. § 1252(a)(2)(D). This includes claims that challenge “whether the 11 BIA applied the correct legal standard in making its determination.” Afridi v. Gonzalez, 12 442 F.3d 1212, 1218 (9th Cir. 2006), overruled on other grounds by Estrada-Espinoza v. 13 Mukasey, 546 F.3d 1147 (9th Cir. 2008) (en banc); see also Rodriguez v. Holder, 683 F.3d 14 1164, 1169 (9th Cir. 2012) (“Whether the BIA has applied the correct standard of review is 15 a question of law.”). And in any case, the Supreme Court recently confirmed that federal 16 courts retain jurisdiction to review the BIA’s determination whether a noncitizen poses a 17 danger to the community. Wilkinson v. Garland, 601 U.S. 209, 212 (2024); Martinez v. 18 Clark, 124 F.4th 775, 779 (9th Cir. 2024).2 19 Thus, the Court has jurisdiction to review Tello’s habeas petition. 20 III. DISCUSSION 21 “[T]he Fifth Amendment entitles [noncitizens] to due process of law in deportation 22 proceedings.” Demore v. Kim, 538 U.S. 510, 523 (2003) (citations omitted). The crux of 23 Tello’s merits argument is that the BIA violated his due process rights by applying the 24

25 2 Respondents suggest that Tello’s claims improperly “re-characteriz[e] an alleged abuse of discretion as a ‘due process’ violation.” Return (dkt. 23) at 7 (quoting Torres-Aguilar v. 26 INS, 246 F.3d 1267, 1271 (9th Cir. 2001)). Aside from the fact that their argument is likely foreclosed by Wilkinson, it misconstrues Tello’s claims. He does not assert that the 27 BIA violated his due process rights by applying the right legal standard in abuse of its 1 incorrect standard of review when it engaged in de novo review of the IJ’s determination 2 that Tello presented a danger to the community. See Am. Pet. ¶¶ 25–26. Tello does not 3 contend, however, that the BIA reached the wrong outcome on de novo review, so the sole 4 question at issue is whether the BIA erred in conducting de novo review rather than review 5 for clear error. 6 Federal regulations provide that the BIA reviews an immigration judge’s findings of 7 fact, such as credibility of witness testimony, for clear error. 8 C.F.R. § 1003.1(d)(3)(i); 8 see Rodriguez v. Holder, 683 F.3d 1164, 1170 (9th Cir.

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Alvarado Tello v. Barr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alvarado-tello-v-barr-cand-2025.