Andres Palacio v. Warden of Cimarron Correctional Facility

District Court, W.D. Oklahoma·Decided April 24, 2026·No. 5:26-cv-00393·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

ANDRES PALACIO, ) ) Petitioner, ) ) v. ) Case No. CIV-26-393-PRW ) WARDEN OF CIMARRON ) CORRECTIONAL FACILITY,1 ) ) Respondents. )

REPORT AND RECOMMENDATION

Petitioner Andres Palacio, a noncitizen proceeding pro se,2 seeks a writ of habeas corpus under 28 U.S.C. § 2241. Doc. 1.3 United States District Judge Patrick R. Wyrick referred the case to the undersigned Magistrate Judge under

1 Pursuant to Fed. R. Civ. P. 25(d), the Court adds Department of Homeland Security (DHS) Secretary Markwayne Mullin, and Todd Blanche (the acting Attorney General) as Respondents. The Warden of Cimarron Correctional Facility is not a federal official, so the response is not filed on behalf of the Warden. See Doc. 7, at 8 n.1.

2 This Report and Recommendation “uses the term ‘noncitizen’ as equivalent to the statutory term ‘alien.’” Nasrallah v. Barr, 590 U.S. 573, 578 n.2 (2020) (citing 8 U.S.C. § 1101(a)(3)). This Court liberally construes a pro se litigant’s pleadings, but cannot serve as Petitioner’s advocate or create arguments on his behalf. Hall v. Bellmon, 935 F.2d 1106, 1110 (10th Cir. 1991); Yang v. Archuleta, 525 F.3d 925, 927 n.1 (10th Cir. 2008).

3 Citations to a court document are to its electronic case filing designation and pagination. Except for capitalization, quotations are verbatim unless otherwise indicated. 28 U.S.C. § 636(b)(1)(B), (C). Doc. 3. Respondents have responded, Doc. 7, and the time for a reply has lapsed. So the matter is at issue.

For the reasons below, the undersigned recommends the Court deny the petition. I. Factual background and procedural history.

Petitioner, a Nicaraguan citizen, alleges he entered the United States on September 1, 2010. Doc. 1, Att. 1, at 1. On August 8, 2025, the Department of Homeland Security (DHS) issued a Notice to Appear (NTA) and charged him as removable as an immigrant allegedly lacking valid immigrant entry documents and as a noncitizen present in the United States without being

admitted or paroled under 8 U.S.C. §§ 1182(a)(6)(A)(i) and 1182(a)(7)(A)(i)(I). Doc. 7, at 9 & Att. 1. Petitioner sought a re-determination of custody, which the Immigration Court denied, finding it lacked jurisdiction to consider the request. Id. at 9 & Att. 2. Petitioner sought cancellation of removal and

adjustment of status on October 1, 2025. Id. at 9-10 & Att. 3. II. Petitioner’s claims. Petitioner raises four grounds for relief: Ground One: prolonged detention in excess of six months in violation of Zadvydas v. Davis, 533 U.S. 678, 701 (2001);

Ground Two: Immigration and Customs Enforcement’s (ICE) prolonged detention of Petitioner violates the Fifth Amendment due process clause; 2 Ground Three: ICE’s violation of the Immigration and Nationality Act and its own regulations violates his due process rights; and

Ground Four: ICE has violated its own regulations under the Administrative Procedure Act.

Doc. 1, at 7-8. Petitioner asks this Court to immediately release him on an order of supervision. Id. at 8. III. Standard of review.

An application for a writ of habeas corpus “is an attack by a person in custody upon the legality of that custody, and . . . the traditional function of the writ is to secure release from illegal custody.” Preiser v. Rodriguez, 411 U.S. 475, 484 (1973). Habeas corpus relief is warranted only if the petitioner “is in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c)(3). “Challenges to immigration detention are properly brought directly through habeas.” Soberanes v. Comfort, 388 F.3d 1305, 1310 (10th Cir. 2004) (citing Zadvydas, 533 U.S. at 687-88). IV. Discussion. A. Petitioner cannot show a deprivation of his due process rights under Zadvydas.

In Grounds One and Two, Petitioner asserts that his prolonged detention violates Zadvydas, and in turn, his substantive due process rights. Doc. 1, at 3 7. This Court may issue a writ of habeas corpus when a person is “in custody in violation of the Constitution or laws or treaties of the United States.” 28

U.S.C. § 2241(c)(3). “The Fifth Amendment’s Due Process Clause forbids the Government to ‘depriv[e]’ any ‘person. . . of . . . liberty . . . without due process of law.’ Freedom from imprisonment—from government custody, detention, or other forms of physical restraint—lies at the heart of the liberty that Clause

protects.” Zadvydas, 533 U.S. at 690. “[W]hen an alien is ordered removed, the Attorney General shall remove the alien from the United States within a period of 90 days.” 8 U.S.C. § 1231(a)(1)(A). This period is called the “removal period.” Id. The removal

period begins once the removal order “becomes administratively final,” § 1231(a)(1)(B)(i), meaning the Board of Immigration Appeals (BIA) has affirmed it on appeal or the time to file an appeal has expired. Id. § 1101(a)(47)(B). In certain enumerated circumstances, an alien “may be

detained beyond the removal period.” Id. § 1231(a)(6); see also Johnson v. Guzman Chavez, 594 U.S. 523, 528-29 (2021) (providing that an alien may be detained beyond the removal period where (1) the alien fails to make a timely application for travel documents or acts to prevent his removal; (2) removal is

not practicable or proper; (3) the alien is inadmissible, removable as a result of violations of status requirements, or there are national security or foreign 4 policy reasons for not removing the alien; or (4) the alien is a risk to the community or unlikely to comply with a removal order).

In Zadvydas, the Supreme Court explained that “[a] statute permitting indefinite detention of an alien would raise a serious constitutional problem.” 533 U.S. at 690. As a result, the Court construed § 1231(a)(6) to limit “an alien’s post-removal-period detention to a period reasonably necessary to bring about

that alien’s removal from the United States.” Id. at 689. “Thus, if removal is not reasonably foreseeable, the court should hold continued detention unreasonable and no longer authorized by statute.” Id. at 699-700. Under Zadvydas, six months of post-removal order detention is

“presumptively reasonable.” Id. at 701. After this point, “once the alien provides good reason to believe that there is no significant likelihood of removal in the reasonably foreseeable future, the Government must respond with evidence sufficient to rebut that showing.” Id. This presumption does not mean

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Andres Palacio v. Warden of Cimarron Correctional Facility, (W.D. Okla. 2026).

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Related

United States Ex Rel. Accardi v. Shaughnessy
347 U.S. 260 (Supreme Court, 1954)
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Soberanes v. Comfort
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Yang v. Archuleta
525 F.3d 925 (Tenth Circuit, 2008)
United States v. Pursley
577 F.3d 1204 (Tenth Circuit, 2009)
Dennis Wayne Moore v. United States
950 F.2d 656 (Tenth Circuit, 1991)
Zadvydas v. Davis
533 U.S. 678 (Supreme Court, 2001)
Nasrallah v. Barr
590 U.S. 573 (Supreme Court, 2020)
Johnson v. Guzman Chavez
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