Juan Ramirez Castaneda v. Todd Lyons, et al.

• Court: District Court, E.D. California
• Decided: June 5, 2026
• Docket: 1:26-cv-01866
• Status: Unknown

Opinion

7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9

10 JUAN RAMIREZ CASTANEDA, Case No. 1:26-cv-01866-JLT-SAB-HC

11 Petitioner, FINDINGS AND RECOMMENDATION TO DENY RESPONDENTS’ MOTION TO 12 v. DISMISS WITHOUT PREJUDICE

13 TODD LYONS, et al., (ECF No. 13)

14 Respondents.

15 16 Petitioner is a federal immigration detainee proceeding with a petition for writ of habeas 17 corpus pursuant to 28 U.S.C. § 2241. 18 I. 19 BACKGROUND 20 Petitioner is a citizen of Colombia who lawfully entered the United States on August 1, 21 2023, with a B-2 visa and remained continuously in the United States thereafter. Petitioner filed 22 an affirmative asylum application with U.S. Citizenship and Immigration Services on March 12, 23 2024, which remains pending. (ECF No. 1 at 4, 5.1) 24 On or about January 27, 2026, Petitioner was stopped during a traffic stop. Petitioner was 25 not cited, and no criminal charge resulted from the stop. U.S. Immigration and Customs 26 Enforcement (“ICE”) took Petitioner into custody, and Petitioner has remained in Department of 27 Homeland Security (“DHS”) custody since January 27, 2026, and has been transferred through 1 multiple facilities. On February 17, 2026, Petitioner was transferred to the California City 2 Correctional Facility, where he is currently detained. Petitioner has no prior criminal record. 3 (ECF No. 1 at 5.) Petitioner requested a custody redetermination pursuant to 8 C.F.R. § 1236. 4 The immigration court did not adjudicate Petitioner’s custody on the merits, instead it “No 5 Actioned” the request on February 19, 2026. (ECF No. 1-2 at 8.) 6 On March 6, 2026, Petitioner filed a petition for writ of habeas corpus, asserting that 7 continued confinement without an individualized bond hearing violated due process and the 8 Immigration and Nationality Act (“INA”). (ECF No. 1.) On April 1, 2026, Respondents filed a 9 motion to dismiss the petition because the immigration court had scheduled a bond hearing for 10 April 9, 2026, and “Petitioner has been provided the process available under the Immigration and 11 Nationality Act to seek release from custody.” (ECF No. 13 at 1.) On April 14, 2026, Petitioner 12 filed an opposition to the motion to dismiss, arguing that because the April 9, 2026 bond hearing 13 was not constitutionally adequate, the petition is not moot and dismissal is not warranted. (ECF 14 No. 15.) To date, no reply in support of the motion to dismiss has been filed, and the time for 15 doing so has passed. 16 II. 17 DISCUSSION 18 Article III of the United States Constitution limits the jurisdiction of federal courts to 19 “actual, ongoing cases or controversies.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477 20 (1990). “This case-or-controversy requirement subsists through all stages of federal judicial 21 proceedings,” which “means that, throughout the litigation, the plaintiff ‘must have suffered, or 22 be threatened with, an actual injury traceable to the defendant and likely to be redressed by a 23 favorable judicial decision.’” Spencer v. Kemna, 523 U.S. 1, 7 (1998) (quoting Lewis, 494 U.S. 24 at 477). 25 Here, Petitioner alleges: 26 At the April 9, 2026 bond hearing, the Immigration Judge indicated that Petitioner would be denied bond based on a purported flight-risk finding tied to the 27 sponsor’s income. Counsel advised the Court that Petitioner’s mother and sponsor had sufficient resources to post a reasonable bond, but the Court’s stated 1 would deny bond on that basis, counsel withdrew the bond request rather than proceed to an inevitable denial premised on an improper standard. 2 3 (ECF No. 15 at 2.) 4 “The party asserting mootness bears the burden of establishing that there is no effective 5 relief remaining that the court could provide.” S. Or. Barter Fair v. Jackson Cnty., 372 F.3d 6 1128, 1134 (9th Cir. 2004). “That burden is always ‘heavy,’ as a case is not moot where any 7 effective relief may be granted[.]” Wild Wilderness v. Allen, 871 F.3d 719, 724 (9th Cir. 2017) 8 (quoting Forest Guardians v. Johanns, 450 F.3d 455, 461 (9th Cir. 2006)). Here, Respondents 9 have not filed a reply in support of the motion to dismiss and have not responded to Petitioner’s 10 allegations regarding what occurred at the April 9, 2026 hearing.2 Petitioner argues that a “bond 11 hearing that is merely scheduled or that occurs but does not provide a constitutionally adequate 12 determination does not moot a detention habeas petition” because “[w]here no valid merits 13 determination has been provided, the Court can still grant effective relief by ordering a prompt, 14 constitutionally adequate hearing or release.” (ECF No. 15 at 2, 3.) Accordingly, at this point in 15 the proceedings, the Court recommends finding that Respondents have not met their heavy 16 burden of establishing that there is no effective relief remaining that the Court could provide and 17 denying the motion to dismiss without prejudice.3 18 II. 19 RECOMMENDATION 20 Accordingly, the Court HEREBY RECOMMENDS that Respondents’ motion to dismiss 21 (ECF No. 13) be DENIED without prejudice. 22 This Findings and Recommendation is submitted to the assigned United States District 23 Court Judge, pursuant to the provisions of 28 U.S.C. § 636 (b)(1)(B) and Rule 304 of the Local 24 Rules of Practice for the United States District Court, Eastern District of California. Within 25 FOURTEEN (14) days after service of the Findings and Recommendation, any party may file 26 written objections with the Court, limited to fifteen (15) pages in length, including any 27 2 The Court notes that no transcript or recording of the hearing has been provided by either party. 1 | exhibits. Such a document should be captioned “Objections to Magistrate Judge’s Findings and 2 | Recommendation.” Replies to the objections shall be served and filed within fourteen (14) days 3 | after service of the objections. The assigned District Judge will then review the Magistrate 4 | Judge’s ruling pursuant to 28 U.S.C. § 636(b)(1)(C). The parties are advised that failure to file 5 | objections within the specified time may waive the right to appeal the District Court’s order. 6 | Wilkerson v. Wheeler, 772 F.3d 834, 839 (9th Cir. 2014) (citing Baxter v. Sullivan, 923 F.2d 7 | 1391, 1394 (9th Cir. 1991)). 8 9 IT IS SO ORDERED. DA 19 | Dated: _ June 5, 2026 ; STANLEY A. BOONE 1] United States Magistrate Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28