Juan Anibal Argueta Palma v. Jeremy Casey, Warden of the Imperial Regional Detention Facility

District Court, S.D. California·Decided July 24, 2026·No. 3:26-cv-03345·Unknown

Opinion

JUAN ANIBAL ARGUETA PALMA, Case No.: 3:26-cv-03345-RBM-VET

Petitioner, ORDER GRANTING PETITION v. FOR WRIT OF HABEAS CORPUS

JEREMY CASEY, Warden of the [Doc. 1] Imperial Regional Detention Facility, Respondent. Pending before the Court is Petitioner Juan Anibal Argueta Palma’s (“Petitioner”) Petition for Writ of Habeas Corpus (“Petition”) pursuant to 28 U.S.C. § 2241. (Doc. 1.) For the reasons set forth below, the Petition is GRANTED. Petitioner, a citizen of El Salvador, is currently detained at the Imperial Regional Detention Facility in the custody of the U.S. Department of Homeland Security (“DHS”). (Doc. 1 at 4). Petitioner was ordered removed from the United States in 1991, 1993, and 2005 due to prior felony convictions. (Doc. 4 at 2; see Doc. 4-1, Ex. 3 at 17.) On June 2, 2017, an immigration judge (“IJ”) denied Petitioner’s application for withholding of removal and protection under the Convention Against Torture (“CAT”). (See Doc. 1-4, Ex. 3 at 11.) Petitioner filed appealed the IJ’s decision with the Board of Immigration Appeals (“BIA”) and filed a motion to reopen his immigration proceedings. (See id.) The BIA dismissed Petitioner’s appeal on February 23, 2018. (See id.) Petitioner was once again removed to El Salvador in March 2018. (See id. at 12.) On February 19, 2019, Petitioner re-entered the United States without inspection and was detained upon entry. (See Doc. 4-1 at 5–6.) The U.S. Department of Homeland Security (“DHS”) reinstated his prior October 2005 order of removal shortly thereafter. (See Doc. 4-1, Ex. 3 at 13.) After an asylum officer determined that Petitioner had a reasonable fear of persecution or torture, Petitioner was placed in withholding-only proceedings on May 21, 2020. (See Doc. 4-1, Ex. 6 at 64–65; Doc. 1-4, Ex. 3 at 11 n. 2.) Petitioner then filed a new application in his withholding-only proceedings for withholding of removal and for deferral of removal under CAT. (See Doc. 1-4, Ex. 3 at 11–12.) On October 9, 2020, an IJ denied Petitioner’s application for withholding of removal and deferral of removal. (See Doc. 1-4, Ex. 3 at 11.) Petitioner filed an appeal of the IJ’s withholding-only decision with the BIA. (See id.) On November 2, 2020, an IJ denied Petitioner’s request for release on bond based on a finding that Petitioner was “a danger to the community and a flight risk.” (Doc. 4-1, Ex. 3 at 16.) Petitioner appealed the IJ’s bond decision with the BIA on November 16, 2020 (see Doc. 4-1, Ex. 4 at 16), but was released under an Order of Supervision on November 25, 2020, “[b]ecause the Agency ha[d] not affected [his] deportation or removal during the period prescribed by law . . . .” (Doc. 1-2 at 5–7; see Doc. 1 at 6.) Petitioner’s release was subject to certain conditions including the use of an ankle monitor and his attendance at regular ICE check-ins. (See Doc. 1 at 4; Doc. 1-2 at 5–7.) An ICE officer removed Petitioner’s ankle monitor during his check-in on March 18, 2022. (Doc. 1 at 4.) On February 11, 2026, Petitioner was arrested and detained while working as a professional truck driver. (Doc. 1 at 4, 6.) Petitioner claims that ICE agents who conducted the arrest falsely told him the BIA has denied his appeal of the IJ’s withholding-only determination on January 31, 2025, but the BIA did not dismiss his appeal until April 20, 2026. (Doc. 1 at 4.) On February 16, 2026, Petitioner was issued with a Notice of Revocation of Release which states that his release on an Order of Supervision was “revoked pursuant to 8 C.F.R. § 241.13(i) for the following reason[ ]: . . . [c]ircumstances have changed such that there is a significant likelihood of removal in the reasonably foreseeable future.” (Doc. 1-2 at 3–4.) The Notice further states that Petitioner would be afforded an informal interview on February 16, 2026. (Id. at 4.) Petitioner also received a Notice to Alien of File Custody Review (“Notice of Custody Review”) indicating that his “custody status will be review on or around May 13, 2026.” (Doc. 1-4 at 17.) The Notice of Custody Review states that: If ICE has not removed [Petitioner] from the United States within the removal period as set forth in INA 241(a) (normally 90-days of either: 1) your entering ICE custody with a final order of removal, deportation or exclusion, or 2) the date of any final order you receive while you are in ICE custody), ICE’s Deciding Official will review [Petitioner’s] case for consideration of release on an Order of Supervision. Release, however, is dependent on [Petitioner] demonstrating to the satisfaction of the Attorney General that [he] will not pose a danger to the community and will not present a flight risk. (Id.) Petitioner claims that he has not been spoken to about his release or pending charges as of May 15, 2026. (See id.) On April 20, 2026, the BIA dismissed Petitioner’s appeal of the IJ’s withholding- only decision. (Doc. 1-4, Ex. 3 at 10–13; see Doc. 4-1, Ex. 5 at 20.) On May 4, 2026, Petitioner filed a petition for relief with the Ninth Circuit challenging the IJ’s withholding- only determination. (Doc. 4 at 2; see Doc. 1-4, Ex. 3 at 3.) On June 1, 2026, Petitioner, proceeding pro se, commenced this action by filing the instant Petition. (Doc. 1.) Respondents filed a Return to the Petition on June 12, 2026. (Doc. 4.) Petitioner has not filed an optional reply brief as of the date of this Order. A writ of habeas corpus is “available 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). “Writs of habeas corpus may be granted by the Supreme Court, any justice thereof, the district courts and any circuit judge within their respective jurisdictions.” 28 U.S.C. § 2241(a). The petitioner bears the burden of demonstrating that “[h]e is in custody in violation of the Constitution or laws or treaties of the United States.” Id. § 2241(c)(3). Petitioner claims that ICE’s revocation of his release under an Order of Supervision and subsequent detention lacked statutory authority in violation of the Fifth Amendment’s Due Process Clause, 8 U.S.C. § 1226(a), and applicable regulations set forth in 8 C.F.R. §§ 241.13, 241.4. (Doc. 1 at 3–8.) Respondents do not respond to Petitioner’s regulatory violation claims. Instead, that “Petitioner is not entitled to release or a bond hearing” because his detention is still within the six-month presumptively reasonable period of detention and 8 U.S.C. § 1231 “provides for mandatory detention of noncitizens with final removal orders.” (Doc. 4 at 2.) As the statutory provision governing Petitioner’s detention determines what procedures Respondents must follow, the Court will address this issue first. A. Detention Authority “Section 1226(a) . . . applies only while ‘a decision on whether the [noncitizen] is to be removed from the United States’ is ‘pending’. . . .” Padilla-Ramirez v. Bible, 882 F.3d 826, 831 (9th Cir. 2017) (quoting 8 U.S.C. §

Juan Anibal Argueta Palma v. Jeremy Casey, Warden of the Imperial Regional Detention Facility, (S.D. Cal. 2026).

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