Carmen Rodriguez Rascon v. Todd Lyons, et al.

CourtDistrict Court, E.D. California
DecidedDecember 22, 2025
Docket1:25-cv-01787
StatusUnknown

This text of Carmen Rodriguez Rascon v. Todd Lyons, et al. (Carmen Rodriguez Rascon v. Todd Lyons, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carmen Rodriguez Rascon v. Todd Lyons, et al., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 CARMEN RODRIGUEZ RASCON, No. 1:25-cv-1787 AC 12 Petitioner, 13 v. ORDER 14 TODD LYONS, et al., 15 Respondents. 16 17 Petitioner, an immigration detainee proceeding through counsel, has filed a petition for a 18 writ of habeas corpus pursuant to 28 U.S.C. § 2241. Currently before the court are petitioner’s 19 motion for an order to show cause (ECF No. 2) and motion for a temporary restraining order 20 (ECF No. 6). Respondents have filed a combined opposition to the motion for a temporary 21 restraining order and answer to the petition in which they also request a stay of the proceedings 22 pending the outcome of the appeal in Rodriguez Vazquez v. Bostock, 779 F. Supp. 3d 1239 23 (W.D. Wash. 2025). ECF No. 13. Petitioner opposes a stay. ECF No. 14 at 8. 24 I. Factual and Procedural Background 25 Petitioner fled his native country, Mexico, due to threats of an unspecified nature. ECF 26 No. at 6-1 at 2, ¶ 3. He was paroled into the United States on April 12, 2024, and he has lived in 27 the country since that time. ECF No. 6 at 8-9. Upon a determination that he was neither a danger 28 to the community or a flight risk, petitioner was released with a Notice to Appear with a first 1 immigration hearing date of March 4, 2026. Id. While released, petitioner was to comply with 2 scheduled check-ins with Immigration and Customs Enforcement (ICE) and never missed an 3 appointment. Id. at 9. On November 12, 2025, petitioner was arrested without a warrant after 4 being stopped at a convenience store on his way to work and has been in detention since. Id. at 8- 5 9. Petitioner has not been afforded a pre-detention hearing or a custody re-determination hearing. 6 Id. 7 On July 8, 2025, the Department of Homeland Security (DHS) issued guidance classifying 8 petitioner under section 235 of the Immigration and Naturalization Act (INA) (8 U.S.C. § 1225) 9 as an “applicant for admission” and therefore subject to mandatory detention. ECF No. 1 at 6. 10 Petitioner asserts that he is being illegally subjected to § 1225’s mandatory detention policy 11 because 8 U.S.C. § 1226(a), which provides broad discretion for release or detention rather than 12 mandating detention, applies to noncitizens already present in the United States. ECF No. 6 at 13 11-12. 14 On September 5, 2025, the Board of Immigration Appeals issued a binding decision that 15 immigration judges have no authority to consider bond requests for any person who entered the 16 United States without admission because they are subject to mandatory detention under 17 § 1225(b)(2)(A). See Matter of Yajure Hurtado, 291 I. & N. Dec. 216, 225 (BIA 2025). 18 On December 9, 2025, petitioner filed a petition for writ of habeas corpus under 28 U.S.C. 19 § 2241 challenging his detention by the DHS. ECF No. 1. The petition asserts two claims for 20 relief. First, petitioner asserts that he has been re-detained and denied a bond hearing under 21 § 1225. ECF No. 1 at 6. This appears to be a claim that the application of § 1225 violates the 22 Immigration and Naturalization Act (INA) because it does not apply to individuals like him.1 Id. 23 at 2, 5-6. Second, petitioner argues that he has a fundamental liberty interest in remaining free 24 from restraint and that his detention without a bond re-determination hearing to determine 25 whether there has been a change in circumstances violates his right to due process. Id. at 6. On 26

27 1 This claim is articulated with more clarity as part of the due process argument in the motion for a temporary restraining order (ECF No. 6 at 11-12) but is sufficiently identified as a separate 28 claim in the petition (ECF No. 1 at 2, 6). 1 December 16, 2025, petitioner filed a motion seeking a temporary restraining order in which he 2 requested that respondents be required to immediately release him from custody and be enjoined 3 from re-detaining him without a pre-deprivation hearing. ECF No. 6 at 8-9. Respondents have 4 opposed the motion for a temporary restraining order.2 ECF No. 13. 5 II. Motion for a Temporary Restraining Order 6 A. Legal Standard for a Temporary Restraining Order 7 The standard for issuing a temporary restraining order is essentially the same as that for 8 issuing a preliminary injunction. Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832, 9 839 n.7 (9th Cir. 2001) (stating that the analysis for temporary restraining orders and preliminary 10 injunctions is “substantially identical”). To obtain either form of injunctive relief, the moving 11 party must show: “[(1)] that he is likely to succeed on the merits, [(2)] that he is likely to suffer 12 irreparable harm in the absence of preliminary relief, [(3)] that the balance of equities tips in his 13 favor, and [(4)] that an injunction is in the public interest.” Winter v. Nat. Res. Def. Council, 14 Inc., 555 U.S. 7, 20 (2008) (citations omitted). “Likelihood of success on the merits ‘is the most 15 important’ Winter factor.” Disney Enters., Inc. v. VidAngel, Inc., 869 F.3d 848, 856 (9th Cir. 16 2017) (quoting Garcia v. Google, Inc., 786 F.3d 733, 740 (9th Cir. 2015)). However, a party 17 seeking injunctive relief must make a showing on all four prongs of the Winter factors to obtain 18 injunctive relief. All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011). 19 //// 20 2 As part of their opposition, respondents argue that petitioner should be required to exhaust 21 administrative remedies. ECF No. 13 at 5-7. Administrative exhaustion is not statutorily required by § 2241 itself. Laing v. Ashcroft, 370 F.3d 994, 997 (9th Cir. 2004) (quoting Castro- 22 Cortez v. INS, 239 F.3d 1037, 1047 (9th Cir. 2001)). However, “[a]s a prudential matter, courts 23 require that habeas petitioners exhaust all available judicial and administrative remedies before seeking relief under § 2241,” though this requirement can be waived. Ward v. Chavez, 678 F.3d 24 1042, 1045 (9th Cir. 2012) (citation omitted). Exhaustion can be waived where “pursuit of administrative remedies would be a futile gesture.” Liang, 370 F.3d at 1000 (quoting SEC v. 25 G.C. George Sec., Inc., 637 F.2d 685, 688 (9th Cir. 1981)). The undersigned finds that 26 exhaustion in this case is waived because “pursuit of administrative remedies would almost certainly be futile given the BIA’s recent holding that all noncitizens detained in the United States 27 without admission are ‘seeking admission’ for purposes of 8 U.S.C. § 1225(b)(2)(A) and must be detained.” Singh v. Andrews, No. 1:25-cv-1543 DJC SCR, 2025 WL 3523057, at *2 (E.D. Cal. 28 Dec. 9, 2025) (citing Matter of Yajure Hurtado, 291 I. & N. Dec. 216 (BIA 2025)). 1 B. Discussion3 2 i. Likelihood of Success on the Merits 3 a.

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Bluebook (online)
Carmen Rodriguez Rascon v. Todd Lyons, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/carmen-rodriguez-rascon-v-todd-lyons-et-al-caed-2025.