Kumar v. Wamsley

CourtDistrict Court, W.D. Washington
DecidedSeptember 17, 2025
Docket2:25-cv-01772
StatusUnknown

This text of Kumar v. Wamsley (Kumar v. Wamsley) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kumar v. Wamsley, (W.D. Wash. 2025).

Opinion

1 2 3

4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 MOHIT KUMAR, CASE NO. 2:25-cv-01772-JHC-BAT 8 Petitioner, ORDER GRANTING PETITIONER’S 9 MOTION FOR A TEMPORARY v. RESTRAINING ORDER 10 CAMILLA WAMSLEY, et al., 11 Respondents. 12 13 14 I 15 INTRODUCTION This matter comes before the Court on Petitioner’s Motion for a Temporary Restraining 16 Order. Dkt. # 2. The Court has reviewed the materials filed in support of and in opposition to 17 the motion, the record, and the governing law. Being fully advised, the Court GRANTS the 18 Motion. 19 II 20 BACKGROUND 21 Petitioner Mohit Kumar is a 26-year-old asylum seeker from India. Dkt. # 2 at 4. He 22 entered the United States from Canada on or about February 6, 2024. Id.; see also Dkt. # 8 at 2. 23 Following entry, Petitioner was apprehended and detained by U.S. Border Patrol. Dkt. ## 2 at 4; 24 1 8 at 2. Border Patrol then processed Petitioner for removal proceedings, issuing a Notice to 2 Appear (NTA) and placing him in removal proceedings. Id. On March 6, 2024, Border Patrol 3 released Petitioner from custody on his own recognizance. Id.

4 It is undisputed that between March 2024 and July 2025, Petitioner complied with all the 5 requirements of his release, including filing a timely application for asylum and appearing for all 6 scheduled check-ins with ICE officers. See generally Dkt. # 8; see also Dkt. # 2 at 5. It is also 7 undisputed that Petitioner received an employment authorization document in November 2024, 8 Dkt. # 2 at 4, has no criminal history, id. at 5, and was residing in California as of July 2025. Id. 9 at 4; see generally Dkt. # 8. 10 On July 17, 2025, Petitioner attended a scheduled check-in at the ICE office in San Jose, 11 California. Dkt. ## 2 at 4; 8 at 3. Petitioner alleges that at the check-in, he informed an ICE 12 officer that he wanted to move to Washington State to seek employment and requested his case

13 be transferred to Washington. Dkt. # 2 at 4. Petitioner further alleges that the ICE officer agreed 14 to Petitioner’s request and granted him permission to transfer his case to the ICE Office in 15 Yakima, Washington. Id. at 5. “Respondents have been unable to verify this claim in the short 16 time allowed for this response.” Dkt. # 8 at 3. 17 On July 21, 2025, Petitioner appeared at the Yakima ICE office for his first check-in in 18 Washington State. Dkt. ## 2 at 5; 8 at 3. According to Petitioner, an ICE officer took Petitioner 19 to a separate room upon arrival at the office, fingerprinted him, and then cuffed his wrists and 20 ankles. Dkt. # 2 at 5. Before the arrest, the officer did not assert that Petitioner was a flight risk 21 or a danger to the community. Id. The officer also did not provide any other legal justification 22 for Petitioner’s re-detention at the time of arrest. Id. Instead, when Petitioner asked why he was

23 being arrested, the officer replied it was because he “came to the wrong place at the wrong time.” 24 Id. The ICE officer’s arrest report similarly fails to provide a legal basis for Petitioner’s re- 1 detention, stating only: “On July 21, 2025, Mohit Kumar was taken into ICE custody after he 2 reported to the Yakima ICE office. Kumar’s case was reviewed and determined that he was 3 amenable to arrest.” Dkt. # 3-1 at 3.

4 According to Respondents, Petitioner’s appearance on July 21, 2025 at the Yakima ICE 5 office was unscheduled. Dkt. # 8 at 3. Upon arrival, an ICE officer noticed that Petitioner “had 6 initially failed to report an address where he could receive mail, had already filed one request to 7 change venue for his immigration proceedings, and had failed to register or provide notice of his 8 new address in Washington prior to his move.” Id. (citations omitted). Due to “these 9 observations and his own experience,” the officer “believed that [Petitioner] may be attempting 10 to delay his immigration proceedings” and “brought his concerns to the attention of the Assistant 11 Field Office Director.” Id. The Assistant Field Office Director revoked Petitioner’s release and 12 “[s]hortly thereafter, a warrant for [Petitioner’s] arrest was issued and executed.” Id.

13 Respondents also note that they “have been unable to verify whether [Petitioner] was informed 14 of the reason for his re-detention on July 21, 2025. Id. at 4. 15 Following the arrest, ICE transferred Petitioner from Yakima to the Northwest ICE 16 Processing Center (NWIPC) in Tacoma, Washington, where he remains detained today. Dkt. ## 17 2 at 6; 8 at 4. Per Respondents, Petitioner requested a bond hearing before an Immigration Judge 18 and was heard on August 11, 2025. Dkt. # 8 at 4. The Immigration Judge denied Petitioner’s 19 bond request, concluding that “the immigration court had no jurisdiction” because Petitioner 20 “was subject to mandatory detention.” Id. 21 Petitioner obtained legal counsel on September 10, 2025. Id. On September 15, 2025, 22 Petitioner filed a petition for writ of habeas corpus under 28 U.S.C. § 2241 in this District. See

23 Dkt. # 1. The same day, Petitioner filed this separate motion, seeking a temporary restraining 24 order (TRO), immediate release, and an order to Respondents to show cause within three days as 1 to why Petitioner’s habeas petition should not be granted. Dkt. # 2. Respondents filed a 2 response to Petitioner’s motion for a TRO on September 17, 2025. Dkt. # 8. Petitioner’s case is 3 set for a final hearing before an Immigration Judge on September 18, 2025. Dkt. ## 2 at 6; 8 at

4 4. 5 III DISCUSSION 6 A TRO is “an extraordinary remedy that may only be awarded upon a clear showing that 7 the plaintiff is entitled to such relief.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 22 8 (2008); Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832, 839 n.7 (9th Cir. 2001) 9 (the standard for issuing a TRO is “substantially identical” to the standard for issuing a 10 preliminary injunction). A plaintiff seeking a TRO must establish: (1) “that he is likely to 11 succeed on the merits”; (2) “that he is likely to suffer irreparable harm in the absence of 12 preliminary relief”; (3) “that the balance of equities tips in his favor”; and (4) “that an injunction 13 is in the public interest.” Winter, 555 U.S. at 20. Alternatively, a petitioner who shows only that 14 there are “serious questions going to the merits” can satisfy the Winter requirements by 15 establishing that the “balance of hardships [] tips sharply towards the plaintiff” and that the 16 remaining two Winter factors are met. All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 17 1131–35 (9th Cir. 2011). For the reasons below, the Court finds that Petitioner has satisfied the 18 four Winter factors. 19 A. Factor One: Likelihood of Success on the Merits 20 Petitioner is likely to succeed on the merits of his due process claim. The Due Process 21 Clause prohibits the federal government from depriving any person of “life, liberty, or property, 22 without due process of law[.]” U.S. Const. Amend. V. This protection extends to “all ‘persons’ 23 within the United States, including [non-citizens], whether their presence here is lawful, 24 1 unlawful, temporary, or permanent.” Zadvydas v. Davis, 533 U.S. 678, 693 (2001). The rights 2 guaranteed by the Due Process Clause also specifically extend to non-citizens in the context of 3 immigration and removal proceedings. See Trump v. J.G.G., 604 U.S.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

De Beers Consolidated Mines, Ltd. v. United States
325 U.S. 212 (Supreme Court, 1945)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Elrod v. Burns
427 U.S. 347 (Supreme Court, 1976)
Reno v. Flores
507 U.S. 292 (Supreme Court, 1993)
Hamdi v. Rumsfeld
542 U.S. 507 (Supreme Court, 2004)
Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Leiva-Perez v. Holder
640 F.3d 962 (Ninth Circuit, 2011)
Tanner Motor Livery, Ltd. v. Avis, Inc.
316 F.2d 804 (Ninth Circuit, 1963)
Preminger v. Principi
422 F.3d 815 (Ninth Circuit, 2005)
Manuel De Jesus Ortega Melendr v. Joseph M. Arpaio
695 F.3d 990 (Ninth Circuit, 2012)
Zadvydas v. Davis
533 U.S. 678 (Supreme Court, 2001)
Hurd v. District of Columbia
864 F.3d 671 (D.C. Circuit, 2017)
Xochitl Hernandez v. Jefferson Sessions
872 F.3d 976 (Ninth Circuit, 2017)
GoTo.Com, Inc. v. Walt Disney Co.
202 F.3d 1199 (Ninth Circuit, 2000)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Kumar v. Wamsley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kumar-v-wamsley-wawd-2025.