Eduardo Populus-Revuelta v. Bruce Scott, Warden, Northwest ICE Processing Center, et al.

CourtDistrict Court, W.D. Washington
DecidedApril 20, 2026
Docket2:26-cv-00636
StatusUnknown

This text of Eduardo Populus-Revuelta v. Bruce Scott, Warden, Northwest ICE Processing Center, et al. (Eduardo Populus-Revuelta v. Bruce Scott, Warden, Northwest ICE Processing Center, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eduardo Populus-Revuelta v. Bruce Scott, Warden, Northwest ICE Processing Center, et al., (W.D. Wash. 2026).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8 EDUARDO POPULUS-REVUELTA, 2:26-cv-00636-RAJ 9 Petitioner, 10 ORDER GRANTING IN PART v. HABEAS PETITION

11 BRUCE SCOTT, Warden, Northwest ICE Processing Center, et al., 12

Respondents. 13

14 15 I. INTRODUCTION 16 THIS MATTER comes before the Court on Petitioner Eduardo Populus-Revuelta’s 17 Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2241 (the “Petition,” Dkt. # 1). 18 Petitioner seeks immediate release or release upon a “reasonable ICE bond,” and an order 19 prohibiting his transfer outside the Western District of Washington during the pendency of 20 this action. Dkt. # 1 at 7. Respondents filed a Return opposing Petitioner’s requests for 21 relief and seeking dismissal of the Petition (the “Return,” Dkt. # 4), along with the 22 supporting declaration of a Deportation Officer employed by U.S. Immigration and 23 Customs Enforcement (“ICE”) (the “Correa Declaration,” Dkt. # 5). For the reasons set 24 forth below, the Court GRANTS IN PART the Petition. 25 1 II. BACKGROUND1 2 Petitioner Eduardo Populus-Revuelta was born in Veracruz, Mexico in 1960. Dkt. 3 # 1 at 2. He was admitted to the United States as a lawful permanent resident on or about 4 January 5, 1966, and has lived in the United States ever since. Id.; Dkt. # 5 ¶ 3. Petitioner 5 is married to a U.S. citizen and has nine children who are citizens. Dkt. # 1 at 2. He 6 previously maintained employment in the mortgage industry and as a handyman. Id. at 3. 7 On July 10, 2016, Petitioner was arrested by the Spokane County Sheriff’s Office 8 for the offense of Rape of a Child First Degree – Attempt, RCW 9A.44.073. Dkt. # 5 ¶ 9 4(a). Petitioner represents that a plea offer was presented in connection with this charge, 10 but that immigration consequences were not discussed before the offer was rejected. Dkt. 11 # 1 at 4. On October 15, 2019, following a jury trial, Petitioner was convicted of Attempted 12 Rape of a Child in the First Degree and sentenced to 81 months of incarceration and lifetime 13 community custody. Id. at 3; Dkt. # 5 ¶ 4(a). The record reflects that Petitioner served 14 approximately 72 months of this sentence before being released directly into ICE custody 15 pursuant to a Notice to Appear (“NTA”) on October 20, 2025. Dkt. # 1 at 3; Dkt. # 5 ¶ 5. 16 Petitioner reports that he has no criminal history except for his 2019 conviction, and that 17 he “received only positive behavioral reports” during his incarceration. Dkt. # 1 at 3. 18 Petitioner’s NTA charges him as removable under Sections 237(a)(2)(A)(iii) and 19 237(a)(2)(E)(i) of the Immigration and Nationality Act (“INA”), on the bases of his 20 conviction of an aggravated felony and of a crime of child abuse, respectively. Dkt. # 5 ¶ 21 5. On December 3, 2025, Petitioner filed an Application for Asylum, Withholding of 22 Removal, and protection under the Convention Against Torture in the Tacoma, Washington 23 Immigration Court. Id. ¶ 7. Petitioner filed an amended Application on February 2, 2026. 24

25 1 This factual background is drawn from the Petition, as well as uncontroverted information from the Return and the Correa Declaration. 1 Id. On February 4, 2026, an Immigration Judge (“IJ”) denied Petitioner’s Application and 2 ordered Petitioner removed to Mexico. Id. ¶ 9; Dkt. # 1 at 3. On February 24, 2026, 3 Petitioner appealed his removal order to the Board of Immigration Appeals (“BIA”); 4 Petitioner’s appeal remains pending. Dkt. # 1 at 3; Dkt. # 5 ¶ 10. Petitioner has not 5 requested a bond hearing in his proceedings before the Immigration Court, and explains 6 that he has not done so because the IJ lacks jurisdiction to grant bond. Dkt. # 1 at 6; Dkt. 7 # 5 ¶ 11; Dkt. # 6 at 2. 8 On the basis of the foregoing, Petitioner asserts that his continued detention violates 9 due process, 8 U.S.C. § 1231(a), and Zadvydas v. Davis, 533 U.S. 678 (2001). Dkt. # 1 at 10 6–7. Petitioner therefore requests that the Court order his immediate release or 11 alternatively release him on a “reasonable ICE bond,” and enter a non-transfer order 12 prohibiting removal from the Western District of Washington during the pendency of this 13 action without prior notice. Dkt. # 1 at 7. 14 15 III. LEGAL STANDARD 16 “Writs of habeas corpus may be granted by . . . the district courts . . . within their 17 respective jurisdictions.” 28 U.S.C. § 2241(a). The district courts’ habeas jurisdiction 18 includes challenges to immigration-related detention. Zadvydas, 533 U.S. at 687. A 19 petitioner may seek habeas relief by showing that he or she is “in custody in violation of 20 the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c). The 21 petitioner bears the burden of proof by a preponderance of the evidence. Davis v. 22 Woodford, 384 F.3d 628, 638 (9th Cir. 2004). 23 IV. DISCUSSION 24 A. Statutory Basis for Petitioner’s Detention 25 Petitioner challenges his “post-order” detention as “unlawful[ly] prolonged” under 1 8 U.S.C. § 1231(a) and Zadvydas. Dkt. # 1 at 2, 5–7. However, as Respondents correctly 2 note, Petitioner is detained under Section 1226(c) of the INA, not Section 1231(a). Dkt. # 3 4 at 1–2. Because Petitioner’s February 4, 2026 removal order remains pending before the 4 BIA, it is not yet final and Petitioner is therefore not yet subject to Section 1231(a) of the 5 INA. See Dkt. # 5 ¶¶ 9–10; Ho v. Noem, No. C25-2222-RSM-MLP, 2025 WL 3466923, 6 at *2 (W.D. Wash. Nov. 24, 2025), report and recommendation adopted, No. C25-2222- 7 RSM, 2025 WL 3471855 (W.D. Wash. Dec. 3, 2025) (petitioner was “not yet subject to a 8 final order of removal and, thus . . . not subject to mandatory detention under § 1231(a)” 9 while his appeal remained pending with the BIA). Petitioner concedes on Reply that he is 10 detained pursuant to Section 1226(c) pending the BIA’s resolution of his appeal. Dkt. # 6 11 at 1. In light of the parties’ agreement regarding the statutory basis for Petitioner’s current 12 detention, the Court assumes that Petitioner’s detention is pursuant to 8 U.S.C. § 1226(c). 13 B. Administrative Exhaustion 14 Respondents argue that this Court should deny the Petition because Petitioner has 15 not exhausted his administrative remedies by seeking a custody redetermination hearing 16 before an IJ. Dkt. # 4 at 3. Petitioner responds that exhaustion is not required because the 17 IJ lacks jurisdiction to grant bond to a detainee held under 8 U.S.C. § 1226(c). Dkt. # 6 at 18 2 (citing 8 C.F.R. § 1003.19(h)(2)(i)(D)).

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Bluebook (online)
Eduardo Populus-Revuelta v. Bruce Scott, Warden, Northwest ICE Processing Center, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eduardo-populus-revuelta-v-bruce-scott-warden-northwest-ice-processing-wawd-2026.