Deepak Sharma (A# 203-703-707) v. Warden of the Golden State Annex Detention Facility, et al.

District Court, E.D. California·Decided April 29, 2026·No. 1:25-cv-01861·Unknown

Opinion

DEEPAK SHARMA (A# 203-703-707), No. 1:25-cv-1861 AC Petitioner, v. ORDER ANNEX DETENTION FACILITY, et al., Respondents. Pursuant to the parties’ consent, all proceedings and entry of final judgment are assigned to the magistrate judge. ECF No. 14. For the foregoing reasons, the petition for writ of habeas corpus is granted in part. I. Factual and Procedural Background Petitioner, a national and citizen of India, entered the United States on or about July 16, 2019. ECF No. 11-1 (Declaration of Deportation Officer Mayra Gallenkamp (“Gallenkamp Decl.”)) ¶ 5. Petitioner was detained by border patrol and issued a Notice to Appear (“NTA”), charging him as inadmissible and ordering him to appear for a future removal hearing. Id. ¶¶ 5 and 7; ECF No. 11-3 (Notice to Appear) at 1. On September 6, 2019, petitioner was released on his own recognizance. ECF No. 11-1 (Gallenkamp Decl.) ¶ 8; ECF No. 11-4 (Notice to EOIR: Alien Address) (“Released from ICE custody on the following condition(s): Order of Supervision or Own Recognizance (Form I-220A)”). The NTA was filed with the Executive Office of Immigration Review (“EOIR”) on February 13, 2020. ECF No. 11-3 (NTA) at 1. The NTA does not indicate that the notice was “being issued after an asylum officer has found that the respondent has demonstrated a credible fear of persecution” or that an expedited removal order under INA § 235(b)(1) was being vacated in light of such finding. Id. Petitioner was arrested on June 5, 2024, and January 2, 2025. ECF No. 11-1 (Gallenkamp Decl.) ¶¶ 9-10; ECF No. 11-5 (RAP Sheet) at 8. On January 7, 2025, petitioner was convicted of assault in violation of California Penal Code § 245. ECF No. 11-1 (Gallenkamp Decl.) ¶ 11; ECF no. 11-5 (RAP Sheet) at 8. On June 25, 2025, petitioner was identified as a potential immigration violator and targeted for detention. ECF No. 11-6 (Form I-213, June 26, 2025) at 2. On June 26, 2025, petitioner was ordered removed to India by an Immigration Judge. Id.; ECF No. 11-8 (Order of Immigration Judge). Before petitioner left the immigration court, Immigration and Customs Enforcement (“ICE”) detained him based on their determination that he was subject to a final order of removal. ECF No. 11-6 (Form I-213, June 26, 2025) at 2. Petitioner was not afforded a pre-detention hearing. ECF No. 1 at 6. On July 15, 2025, petitioner appealed the removal order. ECF No. 11-10 (Filing Receipt for Appeal). The appeal remains pending.1 On December 15, 2025, petitioner filed a habeas petition alleging violations of procedural and substantive due process. ECF No. 1. In response, respondents filed a motion to dismiss or alternatively an opposition to the petition for writ of habeas corpus. ECF No. 11. Petitioner has filed a response to the motion to dismiss and reply to the petition. ECF No. 16. II. The Petition The petition alleges that respondents violated petitioner’s Fifth Amendment due process rights. ECF No. 1 at 5-17. The petition seeks an order (1) declaring petitioner’s detention violates the Due Process Clause of the Fifth Amendment; (2) granting petitioner’s immediate 1 Executive Office of Immigration Review, Automated Case Information, available at https://perma.cc/2B6B-KQMH (last visited April 29, 2026). release or release within 30 days unless respondents schedule a bond hearing before an immigration judge with certain procedural protections; (3) granting any further relief deemed just and proper, and (4) awarding costs and reasonable attorneys’ fees. Id. at 17. III. Legal Standard The Constitution guarantees the writ of habeas corpus “to every individual detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) (citing U.S. Const., art. I, § 9, cl. 2). “The essence 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). The writ of habeas corpus extends to a prisoner who “is in custody in violation of the Constitution or laws or treaties of the United States.” 8 U.S.C. § 2241(c)(3). Historically, “the writ of habeas corpus has served as a means of reviewing the legality of Executive detention, and it is in that context that its protections have been strongest.” I.N.S. v. St. Cyr, 533 U.S. 289, 301 (2001) (citation omitted), superseded by statute on other grounds, Nasrallah v. Barr, 590 U.S. 573580 (2020). “District courts retain jurisdiction under 28 U.S.C. § 2241 to consider habeas challenges to immigration detention that are sufficiently independent of the merits of [a] removal order[.]” Lopez-Marroquin v. Barr, 955 F.3d 759 (9th Cir. 2020) (citation omitted); see also Zadvydas, 533 U.S. at 688 (“We conclude that § 2241 habeas corpus proceedings remain available as a forum for statutory and constitutional challenges to post-removal-period detention.”). IV. Discussion A. Relevant Statutory Framework The United States Supreme Court has acknowledged that “[i]mmigration law can be complex, and . . . is a legal specialty of its own.” Padilla v. Kentucky, 559 U.S. 359, 369 (2010). “Where a [noncitizen] falls within this statutory scheme can affect whether his detention is mandatory or discretionary, as well as the kind of review process available to him if he wishes to contest the necessity of his detention.” Prieto-Romero v. Clark, 534 F.3d 1053, 1057 (9th Cir. 2008). Accordingly, the undersigned begins with the relevant statutory framework. Title 8 U.S.C. § 1225 governs the procedures by which the government may mandatorily detain “an applicant for admission.” Section 1225(a)(1) defines “an applicant for admission” as a noncitizen “present in the United States who has not been admitted or who arrives in the United States (whether or not at a designated port of arrival and including [a noncitizen] who is brought to the United States after having been interdicted in international or United States waters).” 8 U.S.C. § 1225(a)(1). “[A]pplicants for admission fall into one of two categories, those covered by § 1225(b)(1) and those covered by § 1225(b)(2).” Jennings v. Rodriguez, 583 U.S. 281, 287 (2018). Both categories are subject to mandatory detention until a certain point or until certain proceedings have concluded. Id. Of relevance, § 1225(b)(2)(A) states that a noncitizen “applicant for admission” who is “seeking admission” and who does not fall under § 1225(b)(2)(B) exceptions or is subject to subparagraph (C) “shall be detained for a proceeding under section 1229a of this title.” 8 U.S.C. § 1225(b)(2)(A). Despite mandatory detention, applicants for admission may be temporarily released on parole “for urgent humanitarian reasons or significant public benefit” under 8 U.S.C. § 1182(d)(5). Id. at 288 (citing 8 U.S.C. §

Deepak Sharma (A# 203-703-707) v. Warden of the Golden State Annex Detention Facility, et al., (E.D. Cal. 2026).

Deepak Sharma (A# 203-703-707) v. Warden of the Golden State Annex Detention Facility, et al. (Deepak Sharma (A# 203-703-707) v. Warden of the Golden State Annex Detention Facility, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Padilla v. Kentucky
559 U.S. 356 (Supreme Court, 2010)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Immigration & Naturalization Service v. St. Cyr
533 U.S. 289 (Supreme Court, 2001)
Hamdi v. Rumsfeld
542 U.S. 507 (Supreme Court, 2004)
Ocampo v. Holder
629 F.3d 923 (Ninth Circuit, 2010)
William D. Dunne v. Gary L. Henman
875 F.2d 244 (Ninth Circuit, 1989)
Prieto-Romero v. Clark
534 F.3d 1053 (Ninth Circuit, 2008)
Ortega-Cervantes v. Gonzales
501 F.3d 1111 (Ninth Circuit, 2007)
Jennings v. Rodriguez
583 U.S. 281 (Supreme Court, 2018)
Ricardo Lopez-Marroquin v. William Barr
955 F.3d 759 (Ninth Circuit, 2020)