Loua Thor (A-023-881-074) v. Warden of the Golden State Annex Detention Facility, et al.

District Court, E.D. California·Decided April 27, 2026·No. 1:26-cv-01822·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 LOUA THOR (A-023-881-074), No. 1:26-cv-01822-DJC-EFB (HC) 12 Petitioner, 13 v. FINDINGS AND RECOMMENDATIONS 14 WARDEN OF THE GOLDEN STATE ANNEX DETENTION FACILITY, et al., 15 Respondents. 16

17 Petitioner is a noncitizen alien detained in an immigration detention facility who has 18 brought a petition for writ of habeas corpus under 28 U.S.C. § 2241. ECF No. 1. This matter was 19 referred to the undersigned pursuant to Local Rule 302(c)(17). ECF No. 4. For the reasons set 20 forth below, the undersigned recommends the writ be granted. 21 BACKGROUND 22 A. Factual Background 23 In his petition for writ of habeas corpus, petitioner alleges he is a citizen of Laos who 24 entered the United States on an unknown date. ECF No. 1 at 2. He alleges that, in May 2001, he 25 was ordered removed back to Laos and placed under an order of supervision pending his removal. 26 Id. at 2-4. On December 15, 2025, he was arrested by Immigrations and Customs Enforcement 27 (ICE) and is currently detained. Id. at 4. He alleges that ICE has, at present, secured no travel 28 1 documents for petitioner’s removal to Laos. Id. at 2. 2 In their return to the petition, respondents do not dispute that petitioner is a citizen and 3 native of Laos who is subject to a final order of removal. ECF No. 9 at 2. Respondents represent, 4 with supporting documentary evidence, that petitioner entered the United States as a child refugee 5 in 1980 and, in February 2021, he was ordered removed by an Immigration Judge. Id. at 2 & Exs. 6 1-2. That removal order was not appealed and is final. Id. at 2 & Exs. 3-4. In 1994, petitioner 7 was convicted of multiple felonies in California state court and sentenced to twenty-five years-to- 8 life. Id. at 2 & Ex. 1. He was released from incarceration and, relative to his removal order, was 9 required to check in at ICE offices. Id. at 2. On December 15, 2025, an ICE agent arrested 10 petitioner when petitioner appeared at the ICE offices for a check-in appointment. Id. Per 11 respondents, petitioner was arrested “based upon his final order of removal.” Id. at 2 & Ex. 1. 12 Respondents represent that, “ICE advised that they are in the process of procuring travel 13 documents for Petitioner to be removed to Laos” and that petitioner remains currently detained 14 pursuant to 8 U.S.C. § 1231(a)(6). Id. at 2. 15 In his traverse, petitioner does not dispute most of respondents’ factual representations. 16 Petitioner additionally represents that he was incarcerated by the California Department of 17 Corrections and Rehabilitation (CDCR) from 1994 until his release on parole on January 7, 2021. 18 ECF No. 10 at 2. Just prior to his release on parole, on January 6, 2021, he was placed in 19 immigration removal proceedings and issued a Notice to Appear. Id. As a result, when he was 20 released from CDCR custody on January 7, 2021, he was placed into immigration custody 21 pending the competition of removal proceedings. Id. On February 10, 2021, removal order 22 issued; petitioner does not dispute that he did not appeal this order and it is final. Id. He 23 remained in immigration custody until May 12, 2021, when he was released on an order of 24 supervision. Id. Petitioner successfully completed his term of parole relating to his California 25 criminal convictions in January 2024. Id. at 2-3. Simultaneously, and until his arrest by ICE in 26 December 2025, he also complied with the terms of his supervision in his immigration 27 proceeding. Id. Petitioner also obtained his authorization to work in the United States from 28 February 2022 through February 2025. Id. at 3; see also ECF No. 1 at 28. He represents that, 1 since his arrest by ICE on December 15, 2025, he has not been given a bond hearing. ECF No. 2 10 at 3. 3 B. Procedural Background 4 Petitioner initiated this action pro se on March 6, 2026. ECF No. 1. On March 9, 2026, 5 the matter was referred to the undersigned pursuant to Local Rule 302(c)(17). ECF No. 4. The 6 undersigned appointed counsel for petitioner on March 17, 2026. ECF No. 6. On April 2, 2026, 7 respondents filed a return to the petition, ECF No. 9, and, on April 10, 2026, petitioner filed a 8 traverse. ECF No. 10. 9 LEGAL STANDARD 10 The federal court should grant a writ of habeas corpus under 28 U.S.C. § 2241 when the 11 petitioner is in custody in violation of the Constitution or federal law. See, e.g., Dominguez v. 12 Kernan, 906 F.3d 1127, 1134 (9th Cir. 2018). The petitioner bears the burden to prove the 13 unlawfulness of his detention by a preponderance of evidence. See, e.g., Skaftouros v. United 14 States, 667 F.3d 144, 158 (2d Cir. 2011); Sepulveda Ayala v. Bondi, 794 F. Supp. 3d 901, 911 15 (W.D. Wash. 2025). 16 DISCUSSION 17 In his petition, petitioner asserts four claims for relief. In his first claim, he alleges that 18 his continued detention violates his Fifth Amendment due process rights because there is no 19 significant likelihood that he will be removed in the foreseeable future. ECF No. 1 at 14-15. He 20 alleges in his second claim that his removal to a third country would violate the Fifth 21 Amendment, 8 U.S.C. § 1231, the Convention Against Torture, Implementing Regulations, and 22 the Administrative Procedures Act. Id. at 15-16. In his third claim, petitioner alleges that his 23 removal to a third country would violate his rights under the Fifth and Eighth Amendments. Id. at 24 16-17. In his fourth claim for relief, petitioner alleges that his continued detention violates the 25 due process clause of the Fifth Amendment, 8 C.F.R. § 241.13, and the Administrative 26 Procedures Act. Id. at 18-19. As relief, petitioner requests immediate release; an order enjoining 27 respondents from removing petitioner to a third country; and an order enjoining respondents from 28 removing petitioner while his application for pardon from the Governor of California is pending. 1 The undersigned finds petitioner has demonstrated his entitlement to relief on his first and 2 fourth claims and recommends the writ be granted. 3 1. Claim One 4 In petitioner’s first claim for relief, he alleges that his continued detention violates his 5 Fifth Amendment due process rights. ECF No. 1 at 14-15. The undersigned finds petitioner has 6 shown his entitlement to habeas corpus relief by a preponderance of the evidence. 7 “Section 241(a) of the Immigration and Nationality Act (INA), codified at 8 U.S.C. § 8 1231(a), authorizes the detention of noncitizens who have been ordered removed from the United 9 States.” Johnson v. Arteaga-Martinez, 596 U.S. 573, 575 (2022). “In particular, § 1231(a)(6) 10 provides that after a 90-day ‘removal period,’ a noncitizen ‘may be detained’ or may be released 11 under terms of supervision.” Id.

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Loua Thor (A-023-881-074) v. Warden of the Golden State Annex Detention Facility, et al., (E.D. Cal. 2026).

Loua Thor (A-023-881-074) v. Warden of the Golden State Annex Detention Facility, et al. (Loua Thor (A-023-881-074) v. Warden of the Golden State Annex Detention Facility, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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