Jagroop Singh v. Christopher Chestnut, et al.

CourtDistrict Court, E.D. California
DecidedJanuary 27, 2026
Docket1:26-cv-00028
StatusUnknown

This text of Jagroop Singh v. Christopher Chestnut, et al. (Jagroop Singh v. Christopher Chestnut, 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
Jagroop Singh v. Christopher Chestnut, et al., (E.D. Cal. 2026).

Opinion

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 JAGROOP SINGH, Case No. 1:26-cv-00028-JLT-EPG-HC

12 Petitioner, FINDINGS AND RECOMMENDATION TO GRANT PETITION FOR WRIT OF 13 v. HABEAS CORPUS, DENY MOTION FOR PRELIMINARY INJUNCTION AS MOOT, 14 CHRISTOPHER CHESTNUT, et al., DENY RESPONDENTS’ MOTION TO DISMISS, AND DIRECT RESPONDENTS 15 Respondents. TO IMMEDIATELY RELEASE PETITIONER 16 (ECF Nos. 1, 2, 10) 17 18 Petitioner, represented by counsel, is an immigration detainee proceeding with a petition 19 for writ of habeas corpus pursuant to 28 U.S.C. § 2241. For the reasons stated herein, the 20 undersigned recommends granting the petition for writ of habeas corpus on Count Two, denying 21 Respondents’ motion to dismiss, and ordering Petitioner’s immediate release. 22 I. 23 BACKGROUND 24 Petitioner was born in India and entered the United States on July 1, 2024 without 25 inspection and was briefly detained by Department of Homeland Security (“DHS”) based on a 26 Form I-200 Warrant for Arrest of Alien. (ECF No. 1 at 4; ECF No. 1-3 at 3.) On July 1, 2024, 27 Petitioner was released by DHS on an Order of Release on Recognizance. (ECF No. 1 at 4; ECF No. 1-3 at 2, 4.) The conditions of release required Petitioner to be placed on Alternative to 1 Detention (“ATD”) monitoring and mandated that Petitioner check in with Immigration and 2 Customs Enforcement (“ICE”). (ECF No. 1 at 4–5.) On the same date, DHS served Petitioner 3 with a Notice to Appear (“NTA”), which designated him as “an alien present in the United States 4 who has not been admitted or paroled” and charged him with removability pursuant to section 5 212(a)(6)(A)(i) of the Immigration and Nationality Act (“INA”). (ECF No. 1 at 5; ECF No. 1-2 6 at 2.) 7 Following his release from detention, Petitioner timely filed a Form I-589, Application 8 for Asylum, with the immigration court. Petitioner also obtained gainful employment and 9 complied with all the conditions of his order of release. Petitioner has no criminal history. On 10 October 24, 2025, Petitioner was detained during a routine ICE check-in appointment, without 11 prior notice and despite the absence of any alleged violation of release conditions. (ECF No. 1 at 12 5.) 13 On January 5, 2025, Petitioner filed a petition for writ of habeas corpus and motion for 14 temporary restraining order (“TRO”), challenging his detention on substantive and procedural 15 due process grounds and as violative of the Immigration and Nationality Act (“INA”). (ECF Nos. 16 1, 2.) On January 6, 2025, the Court denied the motion for TRO as untimely but converted it to a 17 motion for preliminary injunction and referred the matter to the undersigned. (ECF No. 6.) On 18 January 21, 2026, Respondents filed a motion to dismiss. (ECF No. 10.) That same day, 19 Petitioner filed a reply. (ECF No. 11.) 20 II. 21 DISCUSSION 22 A. Consolidation of Motion for Preliminary Injunction with the Merits 23 In the order setting the briefing schedule, the undersigned indicated that “[g]iven that the 24 petition and the motion for preliminary injunction raise the same claims and seek identical relief, 25 and for purposes of judicial efficiency, it appears to the Court that issuing findings and 26 recommendations on the merits pursuant to Rule 65(a)(2), which provides that ‘the court may 27 advance the trial on the merits and consolidate it with the hearing’ on a motion for preliminary 1 In the motion to dismiss, Respondents “respectfully suggest that if the Court is inclined to 2 grant a preliminary injunction and deny the motion to dismiss the habeas petition, judicial 3 economy counsels that the Court should go further and enter a final judgment granting the 4 petition for writ of habeas corpus on the merits. Respondents do not seek a hearing.” (ECF No. 5 10 at 2.) In the reply, Petitioner requests the Court “[e]nter final judgment consistent with Rule 6 65(a)(2) and Respondents’ own request for judicial economy.” (ECF No. 11 at 7.) 7 Given that the petition and the motion for preliminary injunction raise the same claims 8 and seek identical relief, and for purposes of judicial efficiency, the undersigned recommends 9 “advanc[ing] the trial on the merits and consolidat[ing] it with” the motion for preliminary 10 injunction. Fed. R. Civ. P. 65(a)(2). See Dzhabrailov v. Decker, No. 20-CV-3118 (PMH), 2020 11 WL 2731966, at *4 (S.D.N.Y. May 26, 2020) (considering preliminary injunction and merits of 12 habeas petition simultaneously). See also 28 U.S.C. § 2243 (“The court shall summarily hear and 13 determine the facts, and dispose of [a petitioner’s habeas petition] as law and justice require.”). 14 A. Procedural Due Process 15 In Count Two, Petitioner asserts a violation of his procedural due process rights. (ECF 16 No. 1 at 9–10.) “We examine procedural due process questions in two steps: the first asks 17 whether there exists a liberty or property interest which has been interfered with by the State; the 18 second examines whether the procedures attendant upon that deprivation were constitutionally 19 sufficient.” Kentucky Dep’t of Corr. v. Thompson, 490 U.S. 454, 460 (1989) (internal citations 20 omitted). 21 1. Liberty Interest 22 Respondents argue that “Petitioner is a citizen and national of India who entered the 23 United States illegally. He is then an ‘applicant for admission’ who is subject to mandatory 24 detention by ICE under 8 U.S.C. § 1225(b)(2).” (ECF No. 10 at 2.) 25 “[T]he Due Process Clause applies to all ‘persons’ within the United States, including 26 aliens, whether their presence here is lawful, unlawful, temporary, or permanent.” Zadvydas v. 27 Davis, 533 U.S. 678, 693 (2001). “Freedom from imprisonment—from government custody, 1 protects.” Zadvydas at 690. In Morrissey v. Brewer, 408 U.S. 471 (1972), the Supreme Court 2 addressed whether due process requires a parolee be afforded some opportunity to be heard prior 3 to revocation of parole. 408 U.S. at 472. In examining “the nature of the interest of the parolee in 4 his continued liberty,” the Supreme Court stated: 5 The liberty of a parolee enables him to do a wide range of things open to persons who have never been convicted of any crime. The 6 parolee has been released from prison based on an evaluation that he shows reasonable promise of being able to return to society and 7 function as a responsible, self-reliant person. Subject to the conditions of his parole, he can be gainfully employed and is free 8 to be with family and friends and to form the other enduring attachments of normal life. Though the State properly subjects him 9 to many restrictions not applicable to other citizens, his condition is very different from that of confinement in a prison. . . . The 10 parolee has relied on at least an implicit promise that parole will be revoked only if he fails to live up to the parole conditions. 11 12 Morrissey, 408 U.S. at 482. The Supreme Court found “that the liberty of a parolee, although 13 indeterminate, includes many of the core values of unqualified liberty and its termination inflicts 14 a ‘grievous loss’ on the parolee and often on others” and held that “the liberty is valuable and 15 must be seen as within the protection of” due process. Morrissey, 408 U.S. at 482.

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Bluebook (online)
Jagroop Singh v. Christopher Chestnut, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jagroop-singh-v-christopher-chestnut-et-al-caed-2026.