Francesco Lopez Avina v. Current or Acting Field Office Director, San Francisco Field Office, United States Immigration and Customs Enforcement, et al.

• Court: District Court, E.D. California
• Decided: March 30, 2026
• Docket: 1:26-cv-00204
• Status: Unknown

Opinion

1 2

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ----oo0oo---- 11 12 FRANCESCO LOPEZ AVINA, No. 1:26-cv-00204 WBS SCR 13 Petitioner, 14 v. ORDER DENYING PETITIONER’S 15 MOTION FOR TEMPORARY CURRENT OR ACTING FIELD OFFICE RESTRAINING ORDER 16 DIRECTOR, SAN FRANCISCO FIELD OFFICE, UNITED STATES 17 IMMIGRATION AND CUSTOMS ENFORCEMENT, ET AL., 18 Respondents. 19

20 ----oo0oo---- 21 Although represented by counsel, petitioner Francesco 22 Lopez Avina has filed the instant motion for temporary 23 restraining order pro se. (Docket No. 15.) Petitioner, a 24 citizen of Mexico, entered the United States unlawfully and 25 without inspection in 2000. (See Docket No. 1 at 5.) He has 26 since been arrested for illegally purchasing a firearm in 2022, 27 driving under the influence in 2022, and discharging a firearm in 28 1 2017. (See Docket No. 11 at 2.) Petitioner was also arrested in 2 2018 for using controlled substances and in 2019 for possessing a 3 controlled substance. (See Docket No. 11-1 at 3-6.) 4 On March 3, 2025, petitioner alleges that he was 5 arrested outside his home by Immigration and Customs Enforcement 6 officers and has since been in immigration detention. (Docket 7 No. 1 at 5-6.) He filed the instant motion for temporary 8 restraining order, in which he requests his immediate release 9 from detention, over one year later. (Docket No. 15 at 2.) 10 Standard for Temporary Restraining Order 11 “The standard for a [temporary restraining order] is 12 the same as for a preliminary injunction.” Rovio Entm't Ltd. v. 13 Royal Plush Toys, Inc., 907 F. Supp. 2d 1086, 1092 (N.D. Cal. 14 2012) (citing Stuhlbarg Int'l Sales Co. v. John D. Brush & Co., 15 240 F.3d 832, 839 n.7 (9th Cir. 2001)). Typically, “[a] 16 plaintiff seeking a preliminary injunction must establish that he 17 is likely to succeed on the merits, that he is likely to suffer 18 irreparable harm in the absence of preliminary relief, that the 19 balance of equities tips in his favor, and that an injunction is 20 in the public interest.” Winter v. Nat. Res. Def. Council, Inc., 21 555 U.S. 7, 20 (2008). The last two factors “merge when the 22 Government is the opposing party.” Nken v. Holder, 556 U.S. 418, 23 435 (2009). 24 Likelihood of success on the merits is “the most 25 important factor in determining whether a preliminary injunction 26 is warranted.” Garcia v. County of Alameda, 150 F. 4th 1224, 27 1230 (9th Cir. 2025) (internal citations and quotation marks 28 1 omitted). “[P]laintiffs seeking a preliminary injunction face a 2 difficult task in proving that they are entitled to this 3 extraordinary remedy.” Earth Island Inst. v. Carlton, 626 F.3d 4 462, 469 (9th Cir. 2010) (internal quotation omitted). A mere 5 possibility of success is insufficient to satisfy this factor; 6 instead, a petitioner must demonstrate “a strong likelihood of 7 success on the merits.” Save Our Sonoran, Inc. v. Flowers, 408 8 F. 3d 1113, 1120 (9th Cir. 2005). 9 Background 10 This case, like the dozens of substantially similar 11 cases this court has adjudicated in the last few months, 12 “involves [the] pressing national problem . . . [of] unlawful 13 aliens residing in our country,” Certain Named & Unnamed Non- 14 Citizen Child. & Their Parents v. Texas, 448 U.S. 1327, 1331 15 (1980). The Supreme Court has long “noted” the “dimensions” of 16 this “problem.” I.N.S. v. Delgado, 466 U.S. 210, 223 (1984) 17 (Powell, J., concurring). In 1984, then-recent estimates placed 18 the number of unlawful noncitizens residing in the United States 19 between 2 and 12 million, see id.; the government estimates that 20 number has increased to “at least 15 million people” as of last 21 year, Noem v. Vasquez Perdomo, 146 S. Ct. 1, 1 (2025) (Kavanaugh, 22 J., concurring). 23 Additionally, prior to 1996, “an ‘anomaly’ existed 24 ‘whereby immigrants who were attempting to lawfully enter the 25 United States were in a worse position than persons who had 26 crossed the border unlawfully.’” Chavez v. Noem, 801 F. Supp. 3d 27 1133, 1140 (S.D. Cal. 2025) (quoting Torres v. Barr, 976 F. 3d 28 1 918, 928 (9th Cir. 2020)). Specifically, the provisions of the 2 Immigration and Nationality Act (“INA”) were structured such that 3 “non-citizens who had entered without inspection could take 4 advantage of the greater procedural and substantive rights 5 afforded in deportation proceedings, while non-citizens who 6 presented themselves at a port of entry for inspection were 7 subjected to more summary exclusion proceedings.” Hing Sum v. 8 Holder, 602 F.3d 1092, 1100 (9th Cir. 2010). 9 Against this troubled backdrop, Congress enacted the 10 Illegal Immigration Reform and Immigration Responsibility Act of 11 1996 (“IIRIRA”). See Pub. L. No. 104-208, 110 Stat. 3009 (Sept. 12 30, 1996). IIRIRA “substantially amended the Immigration and 13 Nationality Act of 1952 (‘INA’) and established a new summary 14 removal process for adjudicating the claims of aliens who arrive 15 in the United States without proper documentation.” Smith v. 16 U.S. Customs & Border Prot., 785 F. Supp. 2d 962, 965 (W.D. Wash. 17 2011), aff'd, 741 F.3d 1016 (9th Cir. 2014) (quotations omitted). 18 Relevant here, IIRIRA provides that “[a]n alien present in the 19 United States who has not been admitted or who arrives in the 20 United States . . . shall be deemed . . . an applicant for 21 admission,” 8 U.S.C. § 1225(a)(1), and that such “applicant[s] 22 for admission” are subject to mandatory detention, id. § 23 (b)(2)(A). Thus, among other things, “IIRIRA amended the INA to 24 make admission, not entry, the relevant criterion for removal 25 procedures,” Garibay-Robledo v. Noem, No. 1:25-cv-177-H, 2025 WL 26 3264482, at *4 (N.D. Tex. Sept. 15, 2025), putting an end to the 27 above-described “anomaly,” Chavez, 801 F. Supp. 3d at 1140. 28 1 “For many years” after the enactment of IIRIRA, “the 2 understanding — shared by the Executive and the Supreme Court — 3 was that [8 U.S.C. §] 1226, not [8 U.S.C. §] 1225, governed 4 immigration arrests conducted within the interior of the United 5 States.” Bernal v. Albarran, No. 25-cv-09772 RS, 2025 WL 6 3281422, at *5 (N.D. Cal. Nov. 25, 2025). The government 7 endeavored to correct this understanding last year, when the 8 Departments of Homeland Security (“DHS”) and Justice issued a 9 policy memorandum “requiring all ‘applicants for admission’ . . . 10 to be mandatorily detained during removal proceedings pursuant to 11 [8 U.S.C.] § 1225(b)(2).” Garcia v. Noem, --- F. Supp. 3d ----, 12 2025 WL 2549431, at *1 (S.D. Cal. Sept. 3, 2025) (citation 13 omitted). This memorandum further clarified that such 14 noncitizens were “ineligible” for “bond hearing[s] before an 15 immigration judge and may not be released for the duration of 16 their removal proceedings absent a parole by DHS.” Id. (citation 17 modified). The Board of Immigration Appeals (“BIA”) 18 “subsequently” adopted DHS’ new approach in a “reasoned opinion” 19 concluding that “the practice of conducting bond hearings for 20 aliens who entered the United States without inspection was not 21 supported by the plain language or any reasonable interpretation 22 of the INA.” Liang v. Almodovar, No. 1:25-cv-09322 MKV, 2025 WL 23 3641512, at *4 (S.D.N.Y. Dec. 15, 2025) (citation modified); see 24 Matter of Yajure Hurtado, 29 I. & N. Dec. 216 (BIA 2025) (BIA 25 decision). 26 DHS was entitled to change its interpretation of 8 27 U.S.C. § 1225 as it did last year. Cf. Encino Motorcars, LLC v. 28 1 Navarro, 579 U.S. 211, 221 (2016) (“Agencies are free to change 2 their existing policies as long as they provide a reasoned 3 explanation for the change.”). This change appears to have been 4 precipitated by circumstances which made it a practical 5 necessity. Approximately two months before issuing the policy 6 memorandum, DHS noted that a “mass influx of aliens” was 7 occurring, and that “[w]ithout controls in place . . . to stem 8 the influx,” it would “lose[] its capacity to hold all aliens as 9 required by the INA.” Finding a Mass Influx of Aliens, 90 Fed. 10 Reg. 13622, 13623 (Mar. 25, 2025) (citing 8 U.S.C. § 1225(b)). 11 This influx “present[ed] urgent circumstances requiring an 12 immediate federal response,” id., and the policy memorandum 13 issued shortly thereafter served precisely the function called 14 for by those circumstances. 15 Statutory Framework 16 The court acknowledges at the outset the fluctuating 17 and complex tangle of issues presented by DHS’ recent shift in 18 its approach to detention. See, e.g., Echevarria v. Bondi, No. 19 cv-25-03252 PHX DWL (ESW), 2025 WL 2821282 (D. Ariz. Oct. 3, 20 2025) (noting application of the statutes “as presenting a 21 complicated and debatable question”); cf. Torres v. Barr, 976 F. 22 3d 918, 923 (9th Cir. 2020) (“The complex provisions of the INA 23 have provoked comparisons to a ‘morass,’ a ‘Gordian knot,’ and 24 ‘King Minos’s labyrinth in ancient Crete.” (internal citations 25 and quotation marks omitted)). 26 Here, recent decisions of other judges in the Eastern 27 District of California have largely rejected the government’s 28 1 interpretation of Section 1225(b)(2) as applicable to all 2 “applicants for admission.” See, e.g., Velasquez v. Chestnut, 3 No. 1:26-cv-00576 DJC JDP, 2026 WL 263363, at *1 (E.D. Cal. Feb. 4 2, 2026); Crispin M. C. v. Noem, No. 1:25-cv-01487 KES HBK (HC), 5 2026 WL 70553, at *4-7 (E.D. Cal. Jan. 8, 2026); Singh v. 6 Chestnut, No. 1:26-cv-00330 (HC), 2026 WL 249530, at *2 (E.D. 7 Cal. Jan. 30, 2026). 8 Many decisions of district court judges elsewhere have 9 also reached the conclusion that Section 1226(a), not Section 10 1225(b), provides the appropriate framework for noncitizens 11 already residing in the United States. See, e.g., Perez v. 12 Walsh, No. 1:25-cv-14995, 2026 WL 44777 (N.D. Ill. Jan. 7, 2026); 13 Llanes Tellez v. Bondi, No. 25-cv-08982 PCP, 2025 WL 3677937, at 14 *8 (N.D. Cal. Dec. 18, 2025); Ambroladze v. Maldonado, No. 26-cv- 15 0473 (PKC), 2026 WL 295405, at *2 (E.D.N.Y. Feb. 4, 2026). 16 In contrast, the undersigned has repeatedly found that 17 respondents’ current interpretation of 8 U.S.C. § 1225 comports 18 with that statute’s plain text, whereas petitioner’s 19 interpretation (i.e. respondents’ prior interpretation) does 20 not. See, e.g., J.E.P.M v. WOFFORD, et al., No. 1:26-cv-00316 21 WBS CKD, 2026 WL 125270, at *2 (E.D. Cal. Jan. 16, 2026) 22 (collecting this court’s such cases). In a thorough opinion, 23 the Fifth Circuit recently arrived at the same conclusion. See 24 Buenrostro-Mendez v. Bondi, --- F.4th ----, 2026 WL 323330 (5th 25 Cir. Feb. 6, 2026) (opinion of Jones, J.). The Eighth Circuit 26 has recently reached the same result. See Avila v. Bondi, --- 27 F.4th ----, 2026 WL 819258, at *1 (8th Cir. 2026). 28 1 8 U.S.C. § 1225(b)(2)(A) requires mandatory detention 2 of “an alien who is an applicant for admission, if the examining 3 immigration officer determines that an alien seeking admission is 4 not clearly and beyond a doubt entitled to be admitted.” 5 A neighboring provision, 8 U.S.C. § 1225(a)(1), 6 clarifies that “[a]n alien present in the United States who has 7 not been admitted ... shall be deemed for purposes of this Act an 8 applicant for admission.” The term “admission” is in turn 9 defined “with respect to an alien” as “the lawful entry of the 10 alien into the United States after inspection and authorization 11 by an immigration officer.” Id. § 1101(a)(13)(A) (emphasis 12 added). The inclusion of the word “lawful” in the foregoing 13 definition is critical: it expressly clarifies that an 14 individual may only be considered “admitted” to the United States 15 if their presence therein is with permission. 16 This definition comports with the plain meaning of the 17 word “admit,” which is defined in Merriam-Webster’s Dictionary as 18 “to allow entry (as to a place, fellowship, or privilege).” 19 Admit, Merriam-Webster, https://www.merriam- 20 webster.com/dictionary/admit (last visited Feb. 3, 2026) 21 (emphasis added). To construe the statute otherwise -- “that the 22 mandatory detention provision of 1225 categorically does not 23 apply to aliens who are present in the United States as a result 24 of their illegal entry into the country” -- would “fl[y] in the 25 face of defined statutory text” and contravene the plain meaning 26 of the word “admit.” See Chen v. Almodovar, No. 1:25-cv-8350 27 MKV, 2025 WL 3484855, at *5 (S.D.N.Y. Dec. 4, 2025) (emphasis 28 1 added). 2 By contrast, 8 U.S.C. § 1226(a) states that “[o]n a 3 warrant issued by the Attorney General, an alien may be arrested 4 and detained” pending their final removal decision. “Thus, one 5 express requirement to fall within § 1226(a) — and the critical 6 one here — is that the alien was arrested on a warrant issued by 7 the Attorney General.” Vargas Lopez, 802 F. Supp. 3d 1132, 1139 8 (D. Neb. 2025). Further, pursuant to the Laken Riley Act (the 9 “Act”), subsection (c) of 8 U.S.C. § 1226 was amended to mandate 10 detention for specific categories of noncitizens who have been 11 charged with certain crimes. See 8 U.S.C. § 1226(c)(1)(E); Pub. 12 L. No. 119-1, § 2, 139 Stat. 3, 3 (Jan. 29, 2025) (Laken Riley 13 Act). 14 The term “applicant for admission” in 8 U.S.C. § 1225 15 “functions as a legal designation -- describing an individual's 16 legal status for purposes of the removal scheme.” Alonzo v. 17 Noem, No. 1:25-cv-01519 WBS SCR, 2025 WL 3208284, at *4 (E.D. 18 Cal. Nov. 17, 2025) (collecting cases). And petitioner is 19 subject to this legal designation because he is an “alien,” 8 20 U.S.C. § 1225(a)(1), who is “present in the United States,” id., 21 and who “has not been admitted,” id., since his entry into the 22 United States was not a “lawful entry . . . after inspection and 23 authorization by an immigration officer,” id. § 1101(a)(13)(A). 24 See Mejia Olalde v. Noem, No. 1:25-cv-00168 JMD, 2025 WL 3131942, 25 at *3 (E.D. Mo. Nov. 10, 2025). Petitioner may not “elide[]” 26 this legal designation as an “‘applicant for admission’ merely 27 because he has already entered the United States.” Alonzo, 2025 28 1 WL 3208284, at *4; see also Chen, 2025 WL 3484855, at *4 (same 2 conclusion). 3 Any reliance to the contrary on Jennings v. Rodriguez, 4 538 U.S. 281 (2018), is also misplaced. Jennings did not declare 5 unequivocally that 8 U.S.C. § 1225 does not apply in cases such 6 as petitioner's. Rather, the Supreme Court stated that 8 U.S.C. 7 § 1225(b)(2) “serves as a catchall provision that applies to all 8 applicants for admission not covered by” the more specific 9 categories of § 1225(b)(1). Jennings, 583 U.S. at 287; see also 10 Vargas Lopez, 802 F. Supp. 3d at 1142 (“The Court concludes that 11 the plain language of § 1225(b)(2) and the ‘all applicants for 12 admission’ language of Jennings permit the DHS to detain 13 [petitioner] under § 1225(b)(2).”) Moreover, the Court's 14 introductory language in Jennings dispenses with any remaining 15 doubt by clarifying that “an alien who ‘arrives in the United 16 States,’ or ‘is present’ in this country but ‘has not been 17 admitted,’ is treated as ‘an applicant for admission.’” Id. 18 This court’s interpretation of 8 U.S.C. § 1225 also 19 does not render the Laken Riley Act superfluous. First, 20 “Congress often takes a ‘belt and suspenders’ approach to 21 legislation.” Mejia Olalde, 2025 WL 3131942, at *4 (quoting Atl. 22 Richfield Co. v. Christian, 590 U.S. 1, 14 n.5 (2020)). 23 Second, the Laken Riley Act could not have been passed 24 to affect the application of § 1225, for the simple reason that 25 the Act was passed before respondents’ current interpretation of 26 8 U.S.C. § 1225 was even issued. The Act “could not therefore 27 ‘perform the work’ of the [more] expansive reading of Section 28 1 1225, because that work had not yet been done.” Valencia v. 2 Chestnut, --- F. Supp. 3d ----, 2025 WL 3205133, at *4 (E.D. Cal. 3 Nov. 17, 2025). See Buenrostro-Mendez, 2026 WL 323330, at *7 4 (noting that the Laken Riley Act was passed “at a time when the 5 Executive was still declining to exercise its full enforcement 6 authority under the INA”). 7 Third, and regardless, DHS’ current interpretation of 8 the phrase “applicant for admission” as it appears in 8 U.S.C. § 9 1225 does not render the Act superfluous because “[t]he Attorney 10 General may still exercise her detention discretion under § 11 1226(a) for any other aliens falling under that subsection who 12 are not charged with the specific crimes carved out by” the Act. 13 Chavez, 801 F. Supp. 3d at 1141. 14 “[A]n administrative agency is permitted to change its 15 interpretation of a statute, especially where the prior 16 interpretation is based on error, no matter how longstanding.” 17 Chisholm v. F.C.C., 538 F.2d 349, 364 (D.C. Cir. 1976). For that 18 matter, “[y]ears of consistent practice cannot vindicate an 19 interpretation that is inconsistent with a statute's plain text.” 20 Buenrostro-Mendez, 2026 WL 323330, at *8 (emphasis added). 21 Rectifying prior error is precisely what occurred here. For the 22 above reasons, the court again concludes that 8 U.S.C. § 1225 23 applies to petitioner. 24 Procedural Due Process 25 Petitioner argues that his ongoing detention, which has 26 spanned approximately thirteen months thus far, violates the Due 27 Process Clause because it has no definite termination point. 28 1 (See Docket No. 15 at 2-3.) 2 As petitioner observes, “[a] statute permitting 3 indefinite detention of an alien would raise a serious 4 constitutional problem.” Zadvydas v. Davis, 533 U.S. 678, 690 5 (2001). To date, however, every appellate court to have 6 considered the constitutionality of a petitioner’s prolonged 7 detention has found that the length of such detention did not 8 violate the Due Process Clause. See G.P. v. Garland, 103 F. 4th 9 898, 902 (1st Cir. 2024) (collecting cases). In each of those 10 cases, the length of detention was significantly longer than 11 petitioner’s detention here. See id. at 899 (detention for 12 approximately four years); Soberanes v. Comfort, 388 F.3d 1305, 13 1308 (10th Cir. 2004) (detention for approximately two years); 14 Prieto-Romero v. Clark, 534 F. 3d 1053, 1056 (9th Cir. 2008) 15 (detention for approximately three years); Castaneda v. Perry, 95 16 F. 4th 750, 753 (4th Cir. 2024) (detention for approximately five 17 years); Martinez v. Larose, 968 F.3d 555, 558 (6th Cir. 2020) 18 (detention for approximately two-and-a-half years). 19 Review of those cases reveals that, to determine if a 20 petitioner’s detention appears to be indefinite, courts consider 21 whether: “(1) the petitioner's immigration proceedings have been 22 infected with bad faith or undue delay by the agency; (2) the 23 petitioner's detention is directly associated with a judicial 24 review process that has a definite and evidently impending 25 termination point, and is thus akin to detention during the 26 administrative review process that was upheld by the Supreme 27 Court; and (3) there is evidence that the petitioner is 28 1 unremovable because the destination country will not accept him 2 or his removal is barred by our own laws.” Uulu v. Warden, --- 3 F. Supp. 3d ----, 2026 WL 412204, at *7 (E.D. Cal. Feb. 13, 2026) 4 (citation modified). 5 Petitioner has not provided any evidence that his 6 “immigration proceedings have been infected with bad faith or 7 undue delay.” Id. at *7. He was detained by immigration 8 authorities on March 3, 2025, and immediately placed into removal 9 proceedings. (Docket No. 17 at 3.) He then had a hearing before 10 an immigration judge on December 2, 2025, the outcome of which he 11 appealed. (Id.) These facts are incongruous with a 12 determination that petitioner’s immigration proceedings have been 13 unduly delayed, and petitioner does not allege that these 14 proceedings were infected with bad faith. See Uulu, 2026 WL 15 412204, at *7. 16 Further, petitioner’s detention is “directly associated 17 with a judicial review process,” namely, the appeal of his 18 initial immigration proceedings that petitioner himself chose to 19 initiate. See id. Lastly, there is no evidence that petitioner 20 is stuck in a “‘removable-but-unreviewable limbo,’” as the 21 petitioners in Zadvydas were.” Prieto-Romero, 534 F. 3d at 1063. 22 To the contrary, although petitioner’s “detention lacks a certain 23 end date, . . . this uncertainty alone does not render his 24 detention indefinite in the sense the Supreme Court found 25 constitutionally problematic in Zadvydas.” Id. (emphasis in 26 original). 27 For the above reasons, petitioner has failed to 28 1 demonstrate a likelihood of success on the merits of his 2 procedural due process claim. Thus, the court “need not consider 3 the other preliminary injunction factors.” California v. Azar, 4 911 F.3d 558, 575 (9th Cir. 2018).1 5 Conclusion 6 It bears reiterating once more that Congress has given 7 DHS the very difficult task of ensuring that the millions of 8 aliens who are unlawfully within the United States are detained 9 and removed as prescribed by law. Indeed, “the Department of 10 Justice Inspector General found in 1997 that when aliens are 11 released from custody, nearly 90 percent abscond and are not 12 removed from the United States,” a “situation” that “exists today 13 on a much larger scale.” Buenrostro-Mendez v. Bondi, 2026 WL 14 323330, at *9 (citation modified). It is not the courts’ role to 15 “judge the wisdom or desirability” of how DHS remedies that 16 incongruence. Cf. Heller v. Doe by Doe, 509 U.S. 312, 319 17 (1993). The methods and procedures by which noncitizens are 18 detained undoubtedly involve intricate details which the courts 19 lack the Constitutional authority or practical resources to 20 1 Nevertheless, the court observes that petitioner filed the 21 instant motion on March 26, 2026, but was detained on March 3, 22 2025. (See Docket No. 15.) Petitioner’s one-year filing delay in seeking injunctive relief “implies a lack of urgency and 23 irreparable harm.” See Oakland Trib., Inc. v. Chron. Pub. Co., 762 F.2d 1374, 1377 (9th Cir. 1985). Indeed, “[c]ourts within 24 this circuit have found that delays in seeking temporary restraining orders far shorter than petitioner's [four] month 25 delay to counsel against a finding of irreparable harm.” Singh v. Chestnut, No. 1:26-cv-00273 WBS DMC, 2026 WL 114268, at *1 26 (E.D. Cal. Jan. 15, 2026) (collecting cases). 27

28 ~— DI I IEE I IRI I OIE IE OO OS OEE EEE IRIE IIE Eee dictate. 2 IT IS THEREFORE ORDERED that petitioner’s motion for temporary restraining order (Docket No. 15) be, and the same hereby is, DENIED. ° Pursuant to 28 U.S.C. $ 636(b) (1) (B) and Local General Order No. 262, the case is referred to the assigned magistrate judge for further proceedings. 8 IT IS SO ORDERED. 9 - Dated: March 30, 2026 dd Ld, ak 4 / / WILLIAM B. SHUBB 11 UNITED STATES DISTRICT JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15