Komalpreet Kaur v. United States Department of Homeland Security, et al.

CourtDistrict Court, E.D. California
DecidedDecember 22, 2025
Docket1:25-cv-01726
StatusUnknown

This text of Komalpreet Kaur v. United States Department of Homeland Security, et al. (Komalpreet Kaur v. United States Department of Homeland Security, 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
Komalpreet Kaur v. United States Department of Homeland Security, et al., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 KOMALPREET KAUR,

11 No. 1:25-cv-01726-TLN-SCR Petitioner, 12 13 v. ORDER 14 UNITED STATES DEPARTMENT OF HOMELAND SECURITY, et al., 15 Respondents. 16

17 18 This matter is before the Court on Petitioner Komalpreet Kaur’s (“Petitioner”) Motion for 19 a Temporary Restraining Order (“TRO”). (ECF No. 12.) Respondents United States Department 20 of Homeland Security (“DHS”), Kristi Noem, Pamela Bondi, Todd Lyons, Sergio Albarran, 21 Christopher Chestnut (collectively “Respondents”) filed an opposition. (ECF No. 18.) Petitioner 22 replied. (ECF No. 19.) Parties waived hearing and had no objection to converting the request for 23 TRO into a request for preliminary injunction. (ECF Nos. 18, 20.) For the reasons set forth 24 below, Petitioner’s motion is GRANTED and the Court issues a preliminary injunction.1 25 I. FACTUAL AND PROCEDURAL BACKGROUND 26 Petitioner is a 23-year-old native and citizen of India who is 90 pounds and three months 27 1 The Court previously granted Petitioner’s motion via minute order. (ECF No. 22.) This 28 Order explains the Court’s reasoning. 1 pregnant. (ECF Nos. 12 at 8; 18 at 6.) For the majority of her pregnancy, she has been in 2 immigration detention and she is experiencing medical issues that put her pregnancy at risk, 3 including weight loss and elevated bilirubin levels. (ECF No. 12 at 7.) Her medical issues have 4 necessitated emergency care. (ECF No. 1 at 9–18.) 5 Petitioner arrived in the United States without inspection on December 7, 2024. (ECF No. 6 12 at 8.) She was first apprehended by DHS, then released on her own recognizance on 7 humanitarian grounds on December 17, 2024. (Id.; ECF No. 18 at 11, 13.) As part of her 8 conditions of release, Petitioner is required to check in with U.S. Immigration and Customs 9 Enforcement (“ICE”), keep them informed of her address, and comply with all laws. (ECF No. 10 18 at 13 (Order of Release on Recognizance).) 11 Since her release, Petitioner has applied for asylum and her case is still pending. (ECF 12 No. 12 at 8.) In the meantime, ICE granted her a five-year work permit. (Id.) 13 Petitioner has no criminal record. (Id.) 14 On October 6, 2025, Petitioner appeared for a routine ICE check-in and she was detained. 15 (Id. at 8–9.) The DHS warrant, served on Petitioner at the time of her detention, stated there was 16 “probable cause to believe that [Petitioner] is removable . . . based upon: the pendency of ongoing 17 removal proceedings,” confirmation of Petitioner’s identity, and statements that Petitioner lacked 18 immigration status. (ECF No. 18 at 19.) That is to say, the warrant did not identify any new or 19 changed circumstances which were not already known to DHS. 20 Petitioner reports the conditions at the California City Detention Facility, where she is 21 currently held, are “abysmal.” (ECF No. 12 at 19.) She reports she is malnourished; the 22 temperature in the facility is frigid; she is experiencing regular nosebleeds, insomnia, and 23 physical and mental health issues. (ECF No. 10 at 8.) She describes the water as tasting like 24 bleach or detergent. (Id.) 25 On October 28, 2025, an Immigration Judge denied Petitioner a bond hearing, finding the 26 judge lacked authority to consider the matter due to a Board of Immigration Appeals decision. 27 See Matter of Yajure Hurtado, 291 I. & N. Dec. 216, 225 (BIA 2025) (stripping Immigration 28 Judges of authority to consider bond requests for any person who entered the United States 1 without admission pursuant to a recent DHS policy mandating detention for those persons). (ECF 2 No. 18 at 21–22.) 3 Petitioner was arrested and detained for approximately 2.5 months without a hearing, until 4 December 18, 2025, when this Court issued an order releasing Petitioner to avoid further 5 irreparable harm. (ECF No. 22.) This order explains the Court’s reasoning. 6 II. STANDARD OF LAW 7 A preliminary injunction is an extraordinary remedy. Courts consider whether a petitioner 8 has established: “[1] that [s]he is likely to succeed on the merits, [2] that [s]he is likely to suffer 9 irreparable harm in the absence of preliminary relief, [3] that the balance of equities tips in [her] 10 favor, and [4] that an injunction is in the public interest.” Winter v. Nat. Res. Def. Council, Inc., 11 555 U.S. 7, 20 (2008). Petitioner must “make a showing on all four prongs” of the Winter test. 12 Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011). 13 In evaluating a petitioner’s motion, a district court may weigh a petitioner’s showings on 14 the Winter elements using a sliding-scale approach. Id. A stronger showing on the balance of the 15 hardships may support issuing a preliminary injunction even where there are “serious questions 16 on the merits . . . so long as the [petitioner] also shows that there is a likelihood of irreparable 17 injury and that the injunction is in the public interest.” Id. Simply put, a petitioner must 18 demonstrate, “that [if] serious questions going to the merits were raised [then] the balance of 19 hardships [must] tip[ ] sharply” in petitioner’s favor in order to succeed in a request for a 20 preliminary injunction. Id. at 1134–35. 21 III. ANALYSIS 22 The Court considers each of the Winter elements with respect to Petitioner’s motion. 23 A. Likelihood of Success on the Merits 24 Petitioner asserts she is being detained without notice and a hearing in violation of the 25 Immigration and Nationality Act (“INA”) and her procedural due process rights.2 The Court 26 2 Petitioner also claims violations of substantive due process, federal regulations (8 C.F.R. 27 §§ 212.5, 236.1), and the Administrative Procedures Act because, inter alia, ICE’s conduct runs afoul of its own policies (see ICE Directive: Identification and Monitoring of Pregnant, 28 Postpartum, or Nursing Individuals (2021), https://www.ice.gov/directive-identification-and- 1 addresses each in turn. 2 i. Statutory Claim 3 The Court wearily begins on well-covered ground: Whether § 1225(b)(2) or § 1226(a) 4 governs Petitioner’s immigration detention. Respondents claim Petitioner is subject to mandatory 5 detention under 8 U.S.C. § 1225(b)(2) — a position Respondents take due to a DHS policy 6 change.3 (ECF No. 18 at 1.) Petitioner claims that 8 U.S.C. § 1226(a) applies to her detention, 7 which affords her additional due process including a hearing (ECF No. 12 at 10–13). 8 The issue turns on whether Petitioner is an applicant “seeking admission.” Section 9 1225(b)(2) mandates detention during removal proceedings for applicants “seeking admission” 10 and does not provide for a bond hearing. Section 1226(a) “provides the general process for 11 arresting and detaining [noncitizens] who are present in the United States and eligible for 12 removal.” Rodriguez Diaz v. Garland, 53 F.4th 1189, 1196 (9th Cir. 2022). Under § 1226(a), the 13 Government has broad discretion whether to release, parole, or detain the individual. Id. But § 14 1226(a) also provides several layers of review for an initial custody determination and confers 15 “an initial bond hearing before a neutral decisionmaker, the opportunity to be represented by 16 counsel and to present evidence, the right to appeal, and the right to seek a new hearing when 17 circumstances materially change.” Id. at 1202.

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Komalpreet Kaur v. United States Department of Homeland Security, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/komalpreet-kaur-v-united-states-department-of-homeland-security-et-al-caed-2025.