Balinder Singh v. Timothy S. Robbins, et al.

District Court, E.D. California·Decided February 3, 2026·No. 1:26-cv-00480·Unknown

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 BALINDER SINGH, No. 1:26-cv-00480-DC-SCR 11 Petitioner, 12 v. FINDINGS & RECOMMENDATIONS 13 TIMOTHY S. ROBBINS, et al., 14 Respondents. 15 16 Petitioner is a federal immigration detainee proceeding through counsel in this habeas 17 corpus action filed pursuant to 28 U.S.C. § 2241. This action was referred to the undersigned by 18 operation of Local Rule 302 and 28 U.S.C. § 636(b)(1). 19 I. Factual and Procedural History 20 In light of the overwhelming number of immigration habeas petitions pending in this 21 district and based on the uncontested facts presented in the § 2241 application, the undersigned 22 reproduces the relevant portions of the habeas petition herein. 23 Petitioner is a 33-year-old native and citizen of India. On or about March 8, 2023, Petitioner entered the US, and he was encountered 24 by United States Border Patrol. On March 9, 2023, the Department of Homeland Security (“DHS”) issued a Notice to Appear (“NTA”) 25 under section 212(a)(6)(A)(i) charging him as ‘a[] [noncitizen] present in the United States without being admitted or paroled.’ He 26 was ordered released on recognizance. After he was released, [he] timely filed an I-589, Application for Asylum with US Citizenship 27 & Immigration Services (“USCIS”). His asylum case was pending before the Concord Immigration Court. After his arrival in the 28 United States, Petitioner was subject [] [to] ICE check ins all of 1 which he attended without any failure. He strictly complied with ICE requirements and never violated any conditions imposed on him. On 2 or around December 11, 2025, [] ICE re-detained Petitioner after he attended his ICE check in appointment at the [] Fresno ICE/ERO 3 Center…. [P]etitioner has been detained by Immigration and Customs Enforcement (“ICE”), with no end to petitioner’s detention 4 in the reasonably foreseeable future. 5 ECF No. 1 at 2-3. He is presently detained at the Golden State Annex in McFarland, California. 6 ECF No. 1 at 5. 7 In claim one of his § 2241 application, petitioner raises a Fifth Amendment Due Process 8 challenge to his ongoing and “prolonged detention under § 1225(b) without any individualized 9 assessment of the need for detention….” ECF No. 1 at 10. In claims two and three, petitioner 10 contends that, as a matter of statutory interpretation, his detention falls under the discretionary 11 detention statute codified at 8 U.S.C. § 1226(a) and not § 1225(b). ECF No. 1 at 14-23. By way 12 of relief, petitioner seeks immediate release, or, in the alternative, a bond hearing before an 13 immigration judge where the government bears the burden of proving flight risk or dangerousness 14 by clear and convincing evidence. Id. at 24. 15 Respondents submitted a three page answer to the § 2241 petition asserting that petitioner 16 is subject to mandatory detention pursuant to 8 U.S.C. § 1225(b)(2). ECF No. 8. Moreover, 17 respondents do not challenge the authenticity of the immigration records attached to petitioner’s § 18 2241 application; nor do they submit any additional documents relevant to the pending issues. 19 See ECF No. 3 at 2 (screening order). 20 II. Legal Standards 21 The Constitution guarantees the availability of the writ of habeas corpus “to every 22 individual detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) 23 (citing U.S. Const., Art I, § 9, cl. 2). “The essence of habeas corpus is an attack by a person in 24 custody upon the legality of that custody, and ... the traditional function of the writ is to secure 25 release from illegal custody.” Preiser v. Rodriguez, 411 U.S. 475, 484 (1973). The federal 26 habeas statute confers subject matter jurisdiction over challenges to any individual's confinement 27 “in violation of the Constitution or laws or treaties of the United States[.]” 28 U.S.C. § 28 2241(c)(3). 1 A. Constitutional Framework 2 The Due Process Clause protects persons in the United States from being deprived of life, 3 liberty, or property without due process of law. U.S. Const. amend. V. The Supreme Court has 4 concluded that “the Due Process Clause applies to all ‘persons’ within the United States, 5 including [non-citizens], whether their presence here is lawful, unlawful, temporary, or 6 permanent.” Zadvydas v. Davis, 533 U.S. 678, 693 (2001). This provision “protects individuals 7 against two types of government action: violations of substantive due process and procedural due 8 process.” United States v. Quintero, 995 F.3d 1044, 1051 (9th Cir. 2021) (internal quotation 9 omitted). Freedom from imprisonment or physical restraint is a “fundamental” right at the “core 10 of the liberty protected by the Due Process Clause.” Hernandez v. Sessions, 872 F.3d 976, 993 11 (9th Cir. 2017) (quoting Foucha v. Louisiana, 504 U.S. 71, 80 (1992)). As a matter of substantive 12 due process, governmental action may only infringe a fundamental right if “the infringement is 13 narrowly tailored to serve a compelling state interest.” Reno v. Flores, 507 U.S. 292, 302 (1993). 14 Courts examine procedural due process claims in two steps: the first step is determining 15 whether there exists a protected liberty interest under the Due Process Clause. The second step 16 examines the procedures necessary to ensure any deprivation of that protected liberty interest 17 accords with the Constitution. See Kentucky Dep’t of Corrections v. Thompson, 490 U.S. 454, 18 460 (1989); Morrissey v. Brewer, 408 U.S. 471, 481 (1972) (“Once it is determined that due 19 process applies, the question remains what process is due.”). In deciding what process is due to 20 immigration detainees, the Ninth Circuit has assumed, without deciding, that the three-part test 21 articulated in Mathews v. Eldridge, 424 U.S. 319 (1976), applies. See Rodriguez Diaz, 53 F.4th 22 at 1206-07. Under Mathews, the court considers three factors: (1) the private interest affected; (2) 23 the risk of an erroneous deprivation of that interest; and (3) the government’s interest involved 24 including any fiscal or administrative burden that additional procedures would include. Mathews, 25 424 U.S. at 335. 26 B. Statutory Framework 27 The statutory and regulatory framework governing immigration detention is complex. 28 “Where a [noncitizen] falls within this statutory scheme can affect whether his detention is 1 mandatory or discretionary, as well as the kind of review process available to him if he wishes to 2 contest the necessity of his detention.” Prieto-Romero v. Clark, 534 F.3d 1053, 1057 (9th Cir.

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Balinder Singh v. Timothy S. Robbins, et al., (E.D. Cal. 2026).

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