Karen Elizabeth Rivera-Medrano v. Chad Wolf, Secretary of the Department of Homeland Security, et al.

2020 DNH 055
District Court, D. New Hampshire·Decided April 4, 2020·No. 20-cv-194-JD·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Karen Elizabeth Rivera-Medrano

v. Civil No. 20-cv-194-JD Opinion No. 2020 DNH 055

Chad Wolf, Secretary of the Department of Homeland Security, et al.

O R D E R

Karen Elizabeth Rivera-Medrano, who is being held pending removal proceedings at the Strafford County Department of Corrections (“SCDOC”), has filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 to require the Department of Homeland Security to hold a bond hearing.1 The federal respondents have moved to dismiss the petition. The court previously granted Rivera-Medrano’s unopposed motion for an expedited decision on her petition. Therefore, the petition is addressed and decided on the merits.

1 The petition is brought against the Secretary of the Department of Homeland Security, the Acting Field Office Director, Immigration and Customs Enforcement, Enforcement and Removal Operations, and the Superintendent of the SCDOC. The federal respondents represent that Rivera-Medrano is detained by the Department of Homeland, Immigration and Customs Enforcement. There is no dispute as to the proper party, and the federal respondents are referred as “respondents”.

Background

Rivera-Medrano filed a § 2241 petition with supporting documentation, including her own affidavit. The government filed the affidavit of David T. Wesling, a Supervisory Detention and Deportation Officer for the United States Department of Homeland Security, United States Immigration and Customs Enforcement, Enforcement and Removal Operations, with its memorandum in support of the motion to dismiss. The background information is taken from the facts and documents provided by the parties.

Rivera-Medrano is twenty years old and is from El Salvador.

She entered the United States from Mexico in November of 2017 at Brownsville, Texas, and presented herself to Customs and Border Protection (“CBP”). She sought asylum because she was afraid of returning to El Salvador due to sexual and physical abuse by her stepfather, including rape.

She received a “credible fear interview,” and the asylum officer with the United States Citizenship and Immigration Service (“USCIS”) made a positive determination of her fear claim. At the immigration court hearing, Rivera-Medrano was not represented by counsel, could not afford counsel, and did not speak English. She gave up her asylum claim because of the difficulty of representing herself. An order of removal issued on January 30, 2018, and she was removed back to El Salvador.

Because of her fear of her stepfather, Rivera-Medrano left El Salvador again and went to Mexico where she lived from October of 2018 to July of 2019. On July 27, 2019, near Hildago, Texas, Rivera-Medrano crossed the Rio Grande River on a raft. She then immediately surrendered to CBP authorities.

CBP reinstated Rivera-Medrano’s removal order that was issued on January 30, 2018. Rivera-Medrano filed a petition for withholding of removal, and the USCIS Asylum Office held a reasonable fear interview on August 26, 2019. The USCIS concluded that Rivera-Medrano’s fear was reasonable and referred her case to the Boston Immigration Court for withholding proceedings. The first hearing before an immigration judge was held on October 9, 2019, and the judge told Rivera-Medrano that if she could not find a lawyer by October 29, 2019, she would have to represent herself. The hearing was continued to November 12, 2019, but Rivera-Medrano was unable to find representation and proceed pro se.

At the November 12 hearing, Rivera-Medrano submitted her withholding of removal application to the immigration judge. Her last hearing was held on November 22, and the immigration judge denied her application. Still proceeding pro se, Rivera- Medrano filed an appeal to the Board of Immigration Appeals on December 9, 2019.

The American Civil Liberties Union began representing Rivera-Medrano on January 9, 2020. She then, through counsel, moved to amend her notice of appeal. She also asked for a full decision on the denial of her application for withholding of removal, rather than just the summary that she had received. In addition to her appeal, Rivera-Medrano moved to remand her case to the immigration court to allow her to present new evidence in support of her application for withholding of removal. She has also filed a motion to reopen the underlying removal order that was issued in January of 2018. If these efforts are not successful, Rivera-Medrano intends to appeal to the First Circuit Court of Appeals.

Rivera-Medrano has been detained since July 27, 2019. She has not had a bond hearing, nor is a hearing scheduled. The respondents’ position is that she is not eligible to be released from detention.

Discussion

Federal courts have jurisdiction to decide whether the petitioner is being held “in custody in violation of the Constitution or laws . . . of the United States.” § 2241(c)(3). “[Section] 2241 habeas corpus proceedings [are] available as a forum for statutory and constitutional challenges to post-

removal-period detention.” Zadvydas v. Davis, 533 U.S. 678, 688 (2001).

In support of her petition, Rivera-Medrano contends that her detention is governed by 8 U.S.C. § 1226(a), which entitles her to a bond hearing. The Department contends that Rivera- Medrano is detained pursuant to 8 U.S.C. § 1231(a), which does not give her a right to a bond hearing. Rivera-Medrano responds that even if § 1231(a) governs her detention, she is entitled to a bond hearing under the due process clause of the Fifth Amendment because of the length of her detention. The respondents disagree.

A. Statutory Framework Section 1226(a) provides that “an alien may be arrested and detained pending a decision on whether the alien is to be removed from the United States.” See also Jennings v. Rodriguez, 138 S. Ct. 830, 837 (2018). An alien detained under § 1226(a) is entitled to an individualized bond hearing before an immigration judge to determine whether continued detention is necessary. Guzman Chavez v. Hott, 940 F.3d 867, 873-74 (4th Cir. 2019); Guerrero-Sanchez v. Warden, York County Prison, 905 F.3d 208, 214 (3d Cir. 2018). Under § 1226(c), certain aliens may not be released pending a decision on removal because they have been convicted of particular crimes, and there is no

statutory provision for a bond hearing in those circumstances. Jennings, 138 S. Ct. at 837; Reid v. Donelan, 390 F. Supp. 3d 201, 213-14 (D. Mass. 2019).

An alien who has been removed previously and then reenters the United States without authorization is subject to the prior removal order, which is reinstated from its original date. § 1231(a)(5); Guzman Chavez, 940 F.3d at 869. “Except as otherwise provided in [§ 1231], when an alien is ordered removed, the Attorney General shall remove the alien from the United States within a period of 90 days (in this section referred to as the “removal period).” § 1231(a)(1)(A). If the alien is not removed during the 90-day removal period, he or she may be released subject to supervision. § 1231(a)(3).

Certain aliens, who are inadmissible under 8 U.S.C. § 1182;

removable under 8 U.S.C. §§ 1227(a)(1)(C), 1227(a)(2), or 1227(a)(4); or have been determined to be a risk to the community or unlikely to comply with the removal order, may not be released as provided in § 1231(a)(3). § 1231(a)(6). There is no provision in § 1231(a)(6) for release and no explicit statutory time limit on detention. Zadvydas, 533 U.S. at 689 (imposing an implicit time limit on detention “to a period reasonably necessary to bring about that alien’s removal from the United States”); Guerrero-Sanchez, 905 F.3d at 214.

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Karen Elizabeth Rivera-Medrano v. Chad Wolf, Secretary of the Department of Homeland Security, et al., 2020 DNH 055 (D.N.H. 2020).

2020 DNH 055 (Karen Elizabeth Rivera-Medrano v. Chad Wolf, Secretary of the Department of Homeland Security, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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