Mamadou Sall v. Christopher Bullock, New Orleans Field Office Director of Immigration and Customs Enforcement, Enforcement and Removal Operations

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION MAMADOU SALL, ) ) Petitioner, ) ) v. ) CHRISTOPHER BULLOCK, New Orleans ) No. 2:26-cv-02889-SHL-atc ) Field Office Director of Immigration and ) Customs Enforcement, Enforcement and Removal Operations,1 ) ) Respondent. )

ORDER STAYING TRANSFER AND REQUIRING RESPONSE

On July 20, 2026, Petitioner Mamadou Sall filed the Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2241. (ECF No. 1.) Sall challenges his continued detention “without any individualized bond determination.” (Id. at PageID 1.) Sall, a citizen of Senegal, “entered the United States seeking protection from persecution.” (Id.) He was taken into ICE custody at an unknown date and remains detained at the West Tennessee Detention Facility. He seeks immediate release from Respondent’s custody. (Id. at PageID 3.) On May 11, the Sixth Circuit issued the opinion in Lopez-Campos v. Raycraft, 175 F.4th 713 (6th Cir. 2026), affirming that a noncitizen who has spent “significant time . . . within the interior of the United States,” and who has not committed an offense rendering them ineligible under § 1226(c), may not be detained without an individualized bond hearing. 175 F.4th at 734.

1 The only proper Respondent in this action is Christopher Bullock, Field Office Director of Enforcement and Removal Operations, New Orleans Field Office, Immigration and Customs Enforcement. See Rosciszewski v. Adducci, 983 F. Supp. 2d 910, 913–14 (E.D. Mich. 2013) (“[T]he ICE District Director is the proper respondent in a habeas petition brought by an alien, since the District Director has power over such aliens.”). Accordingly, Todd M. Lyons, Mellissa B. Harper, and Trinity Minter are dismissed from the case. Upon review of the Petition, it is ORDERED as follows: (1) Within three business days of the filing of this Order, Petitioner shall deliver a copy of the Petition and this Order to the United States Attorney for the Western District of Tennessee electronically at the following email address: stuart.canale@usdoj.gov.

(2) Within three business days after Petitioner complies with the above requirement, Respondent shall respond to the Petition in writing. If the basis of Petitioner’s detention is 8 U.S.C. § 1225(b)(2)(A) and Respondent continues to oppose release, Respondent shall either distinguish this case from Lopez-Campos v. Raycraft, 175 F.4th 713 (6th Cir. 2026), or state why Lopez-Campos otherwise does not apply. If no such showing is made, Respondent shall state whether he consents to the issuance of the writ. (3) Petitioner may file a reply within three business days after Respondent’s responsive filing. (4) Respondent shall not transfer Petitioner out of the West Tennessee Detention Facility during the pendency of the Petition.

IT IS SO ORDERED, this 21st day of July, 2026. s/ Sheryl H. Lipman SHERYL H. LIPMAN CHIEF UNITED STATES DISTRICT JUDGE