Jose de Jesus Duran Moreno v. U.S. Attorney General, et al.

CourtDistrict Court, E.D. California
DecidedJune 11, 2026
Docket1:26-cv-02249
StatusUnknown

This text of Jose de Jesus Duran Moreno v. U.S. Attorney General, et al. (Jose de Jesus Duran Moreno v. U.S. Attorney General, 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
Jose de Jesus Duran Moreno v. U.S. Attorney General, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JOSE DE JESUS DURAN MORENO, Case No. 1:26-cv-02249-JLT-HBK (HC) 12 Petitioner, FINDINGS AND RECOMMENDATIONS TO GRANT PETITION FOR WRIT OF HABEAS 13 v. CORPUS1 14 U.S. ATTORNEY GENERAL, et al., (Doc. 1) 15 Respondents. FIVE-DAY OBJECTION PERIOD 16 17 18 Petitioner Jose de Jesus Duran Moreno, an immigrant detainee in U.S. Immigration 19 Customs and Enforcement (“ICE”) custody at the California City Immigration Processing Center 20 in California City, California, initiated this action by filing a pro se petition for writ of habeas 21 corpus under 28 U.S.C. § 2241 on January 9, 2026. (Doc. 1, “Petition”). Liberally construed, the 22 Petition raises four grounds for relief: (1) Petitioner is “lawfully” in the United States because he 23 was approved for Temporary Protected Status (“TPS”); (2) his detention without a bond hearing 24 violates his procedural due process rights under the Fifth Amendment; (3) his “indefinite” 25 detention violates his substantive due process rights; and (4) the conditions of his detention are 26 1 This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302 27 (E.D. Cal. 2025).

28 1 harmful to his mental and physical health. (Id. at 6-7). As relief, Petitioner seeks, inter alia, 2 immediate release from custody. (Id. at 7). On May 15, 2026, Petitioner moved for temporary 3 restraining order, which assigned district judge denied as untimely on May 18, 2026. (Docs. 9, 4 10). 5 Respondents file a two-page response arguing the Court should deny the Petition because 6 (1) Petitioner is subject to mandatory detention under 8 U.S.C. § 1225(b)(2) as an “applicant for 7 admission,” and thus is ineligible for a bond hearing; and (2) Petitioner “does not possess a right 8 to freedom from immigration detention in any form other than the form provided by Congress.” 9 (Doc. 6 at 1-2). Petitioner did not file a reply, and the deadline to do so has passed. (See docket). 10 Significant here is Petitioner’s status as a Venezuelan citizen who was detained at the 11 border and later released. For the reasons below, the undersigned recommends that the district 12 court grant the Petition on Petitioner’s procedural due process claim (claim two).2 13 I. BACKGROUND 14 Petitioner is a native and citizen of Venezuela who entered the United States without 15 inspection on May 4, 2023, and was detained almost immediately. (Doc. 6-1 at 2). DHS 16 determined he was subject to removal under 8 U.S.C. § 1182(a)(7)(i)(I) (alien not in possession of 17 valid entry document). (Id.). On May 16, 2023, ICE enrolled Petitioner in the Alternatives to 18 Detention (“ATD”) program and required him to report to a scheduled appointment regarding his 19 immigration case. (Doc. 6-3). 20 On February 15, 2026, Florida patrol officers conducted a vehicle stop for a traffic 21 violation and took Petitioner into custody after determining he was “illegally in the United 22 States.” (Doc. 6-2 at 2). At the time the Petition was filed, Petitioner remained detained in ICE 23 custody at the California City Immigration Processing Center. (Id. at 3). 24 //// 25 //// 26

27 2 In light of the Court’s conclusion that Petitioner’s re-detention was in violation of his procedural due process rights under the Fifth Amendment, and recommendation that Petitioner be released immediately, 28 the Court declines to address Petitioner’s additional claims for relief. 1 II. APPLICABLE LAW AND ANALYSIS 2 Under 28 U.S.C. § 2241(c)(3), a district court may grant a writ of habeas corpus when the 3 petitioner “is in custody in violation of the Constitution or laws or treaties of the United States.” 4 District courts retain jurisdiction under § 2241 to consider habeas challenges to immigration 5 detention that are sufficiently independent of the merits of a removal order. Lopez-Marroquin v. 6 Barr, 955 F.3d 759, 759 (9th Cir. 2020) (citing Singh v. Holder, 638 F.3d 1196, 1211–12 (9th Cir. 7 2011)); see also Jennings v. Rodriguez, 538 U.S. 281, 294 (2018). 8 A. Statutory and Legal Framework 9 As background, the Court will briefly outline the statutory framework of detention 10 authority under the INA, and the recent shift by Executive agencies in interpreting these statues. 11 1. Mandatory Detention under 8 U.S.C. § 1225(b) 12 Section 1225(a)(1) provides that an alien present in the United States who has not been 13 admitted, or who arrives in the United States, is deemed an “applicant for admission.” Applicants 14 for admission must be inspected by immigration officers consistent with U.S. immigration law. 15 Jennings, 583 U.S. at 287 (quoting § 1225(a)(3)). If an immigration officer determines that an 16 arriving alien is inadmissible and the alien does not indicate an intention to apply for asylum or 17 express a fear of persecution, the officer must order the alien removed without further hearing or 18 review. § 1225(b)(1)(A)(i); 8 U.S.C. § 1182(a)(7). With certain exceptions, § 1225(b)(2)(A) 19 directs that if am applicant for admission is not “clearly and beyond a doubt” entitled to be 20 admission, “the alien shall be detained” for removal proceeding under 1229a. § 1225(b)(2)(A) 21 (emphasis added). Applicants for admission may be released on parole only for :urgent 22 humanitarian reasons or significant public benefit.” Jennings, 583 U.S. at 288 (quoting 8 U.S.C. 23 § 1182(d)(5)(A) and citing 8 C.F.R §§ 212.5(b), 235.3 (2017)). 24 //// 25 //// 26 //// 27 //// 28 //// 1 2. Discretionary Detention under 8 U.S.C. § 1226(a)3 2 Section 1226(a) authorizes the arrest and detention of an alien pending a decision on 3 removal, and grants the government broad discretion to continue detention or release the alien on 4 bond or conditional parole. § 1226(a); Rodriguez Diaz v. Garland, 53 F.4th 1189, 1196 (9th Cir. 5 2022) (citing 8 C.F.R. § 236.1(c)(8)). Federal regulations provide that noncitizens detained under 6 § 1226(a) receive bond hearings at the outset of detention, where they must show by a 7 preponderance of the evidence that they are not a danger to the community or a flight risk. 8 Jennings, 583 U.S. at 306 (citing 8 C.F.R. § 236.1(d)(1)); Matter of Guerra, 24 I.& N. Dec. 37, 9 40 (B.I.A. 2006); Ortega-Cervantes v. Gonzales, 501 F.3d 1111, 1115 (9th Cir. 2007).

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Jose de Jesus Duran Moreno v. U.S. Attorney General, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jose-de-jesus-duran-moreno-v-us-attorney-general-et-al-caed-2026.