A.M. v. Kevin Joyce, Sheriff, Cumberland County, et al.

CourtDistrict Court, D. Maine
DecidedDecember 22, 2025
Docket2:25-cv-00615
StatusUnknown

This text of A.M. v. Kevin Joyce, Sheriff, Cumberland County, et al. (A.M. v. Kevin Joyce, Sheriff, Cumberland County, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A.M. v. Kevin Joyce, Sheriff, Cumberland County, et al., (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF MAINE

A.M., ) ) Petitioner ) ) v. ) No. 2:25-cv-00615-LEW ) KEVIN JOYCE, Sheriff, Cumberland ) County, et al., ) ) Respondents )

ORDER ON PETITION FOR WRIT OF HABEAS CORPUS

Before the Court is Petitioner A.M.’s Petition for Writ of Habeas Corpus (ECF No. 1) and Emergency Motion for a Temporary Restraining Order and Preliminary Injunction (ECF No. 3). Petitioner seeks release from immigration detention. Federal Respondents oppose the Petition. For the following reasons, the Petition and Motion are denied without a hearing.1 BACKGROUND The following background statement is drawn from the Petition, the Return and Response, and exhibits introduced in support of those filings.

1 Neither party has requested a hearing. See also Tijerina v. Thornburgh, 884 F.2d 861, 866 (5th Cir. 1989) (finding that although 28 U.S.C. § 2243 requires the court to “summarily hear and determine the facts,” the court need not hold an evidentiary hearing “[w]here the [habeas] petitioner raises only questions of law, or questions regarding the legal implications of undisputed facts”) (collecting case). Petitioner A.M. is a citizen and national of Afghanistan. Petitioner’s presence in the United States is the product of his service to the United States in military missions in

Afghanistan and an approval issued by the U.S. Government’s Chief of Mission in Afghanistan and an associated Special Immigrant Visa (“SIV”). Pet. Ex. D. (ECF No. 1- 4). See Afghan Allies Protection Act of 2009 (“AAPA”), Pub. L. No. 111-8, § 602(a), 123 Stat. 807 (2009), codified as amended in 8 U.S.C. § 1101 note. The Notice of Action (Form I-797) associated with the SIV states that the SIV “does not in itself grant any immigration status and does not guarantee that the alien beneficiary will subsequently be

found to be eligible for a visa, for admission to the United States, or for an extension, change, or adjustment of status.” Id. In other words, despite his SIV status, Petitioner has never been “admitted” to the United States. Instead, after vetting, Petitioner was paroled into the United States under 8 U.S.C. § 1182(d)(5) (INA § 212(d)(5)). Pet. ¶ 20.2 Petitioner’s initial parole period was two years, which was extended by administrative

action until September 6, 2025. Id. When brought to the United States, Petitioner was accompanied by a woman understood to be his spouse and nine children. They have lived in the Boston area for roughly four years. Since their arrival, the family has added two more children. In October 2023, Petitioner applied for lawful permanent resident status. On

September 8, 2025, after the conduct of a variety of procedural measures, U.S. Citizenship and Immigration Services (“USCIS”) issued a Notice of Decision informing Petitioner that

2 Petitioner has not alleged or demonstrated that his receipt of the SIV was an admission event or was the equivalent of admission. his application was denied based on certain adverse findings. Gov’t Ex. 2. Also on September 8, 2025, USCIS issued to Petitioner by mail a Notice to Appear before an

immigration judge in Boston on February 3, 2026, in connection with removal proceedings. Pet. Ex. E; Gov’t Ex. 3. On December 5, 2025, an immigration officer signed a warrant for arrest of alien, directing “[a]ny immigration officer authorized pursuant to sections 236 and 287 of the Immigration and Nationality Act and part 287 of title 8, Code of Federal Regulations,” to arrest Petitioner based on probable cause that Petitioner is “removable.” Gov’t Ex. 4.

Petitioner was arrested that day and has been detained ever since. Pet. ¶¶ 4, 5, 24. On December 11, 2025, Petitioner filed for habeas corpus relief pursuant to 28 U.S.C. § 2241. Following receipt of the Verified Petition, the Court issued an Order to Show Cause that directed the Respondents to address the merits of the Petition. See 28 U.S.C. § 2243. Federal Respondents filed their timely Return and Response and Petitioner

has filed his Reply. Neither party has suggested the need for an evidentiary presentation in this matter. Instead, they present only legal argument in support of their respective positions. DISCUSSION A court may grant a writ of habeas corpus to a petitioner who demonstrates his or

her detention is in violation of the constitution or federal law. 28 U.S.C. § 2241. The petitioner bears the burden of proving that his detention violates “the Constitution or laws or treaties of the United States.” Id. § 2241(c)(3). 3

Petitioner alleges that his recent arrest and ongoing detention violate the Due Process Clause because the arrest did not occur “forthwith” following the expiration of his parole and he is, therefore, entitled to a bond hearing. Pet., Count I. Petitioner also alleges that he is held in violation of the Equal Protection Clause because he is detained based on the President’s negative statements concerning Afghanistan and aliens of Afghan origin. Id., Count II. Petitioner requests immediate release.

A. Due Process The Fifth Amendment provides that “[n]o person shall be . . . deprived of life, liberty, or property, without due process of law.” U.S. Const. am. V. The Fifth Amendment applies to aliens facing removal proceedings. Reno v. Flores, 507 U.S. 292, 306 (1993). In Hernandez-Lara v. Lyons, the First Circuit held that “due process requires

the government to either (1) prove by clear and convincing evidence that [an alien] poses a danger to the community or (2) prove by the preponderance of the evidence that she poses a flight risk” in order to impose detention throughout the period of removal proceedings, including appeals. 10 F.4th 19, 41 (1st Cir. 2021). The Hernandez-Lara requirement

3 The exercise of jurisdiction over this matter is proper because it presents a challenge to the lawfulness of detention and is not meant to review or interfere with the underlying removal proceedings. Demore v. Kim, 538 U.S. 510, 516-17 (2003) (hearing habeas claim because it challenged the “statutory framework that permits detention without bail” rather than an exercise of discretion by the Secretary); Kong v. United States, 62 F.4th 608, 614 (1st Cir. 2023) (quoting Aguilar, 510 F.3d at 11); Hernandez-Lara v. Lyons, 10 F.4th 19, 33 (1st Cir. 2021) (same, “cabin[ing] the discretion granted [to the Attorney General] through the constitutional restraints applicable to all government action,” while preserving the Attorney General’s ability to exercise discretion “within those limits”). rested on a Mathews v. Eldridge due process analysis for a non-criminal alien who unlawfully entered the United States without being processed at the border. Id. at 27-35.

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A.M. v. Kevin Joyce, Sheriff, Cumberland County, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/am-v-kevin-joyce-sheriff-cumberland-county-et-al-med-2025.