Mandeep Singh Sandhu v. Minga Wofford, et al.

E.D. California

Mandeep Singh Sandhu v. Minga Wofford, et al.

DecidedDecember 9, 2025

Docket1:25-cv-00972

StatusUnknown

This text of Mandeep Singh Sandhu v. Minga Wofford, et al. (Mandeep Singh Sandhu v. Minga Wofford, 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.

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Mandeep Singh Sandhu v. Minga Wofford, et al., (E.D. Cal. 2025).

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2 3 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8

9 MANDEEP SINGH SANDHU, Case No. 1:25-cv-00972-SAB-HC

10 Petitioner, FINDINGS AND RECOMMENDATION TO DISMISS PETITION FOR WRIT OF 11 v. HABEAS CORPUS AS MOOT

12 MINGA WOFFORD, et al., ORDER DIRECTING CLERK OF COURT TO RANDOMLY ASSIGN DISTRICT 13 Respondents. JUDGE

14 15 Petitioner, represented by counsel, is proceeding pro se with a petition for writ of habeas 16 corpus pursuant to 28 U.S.C. § 2241. 17 I. 18 BACKGROUND 19 On August 5, 2025, Petitioner filed the instant petition for writ of habeas corpus. (ECF 20 No. 1). Petitioner alleged that he has been detained by U.S. Immigration and Customs 21 Enforcement (“ICE”) beyond the removal period authorized by law, in violation of the Fifth 22 Amendment, 8 U.S.C. § 1231(a)(6), and implementing regulations. (ECF No. 1 at 8–9.1) 23 Petitioner requested release from custody. (Id. at 10.) On October 7, 2025, Respondents filed a 24 response, and on October 21, 2025, Petitioner filed a reply. (ECF Nos. 13, 14.) On November 20, 25 2025, Respondents filed a notice, which states: “According to Immigration and Customs 26 Enforcement, Mr. Sandhu has been deported to India. Given that, it appears this matter is now 27 mooted.” (ECF No. 20.) 1 II. 2 DISCUSSION 3 Article III of the United States Constitution limits the jurisdiction of federal courts to 4 “actual, ongoing cases or controversies.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477 5 (1990). “This case-or-controversy requirement subsists through all stages of federal judicial 6 proceedings,” which “means that, throughout the litigation, the plaintiff ‘must have suffered, or 7 be threatened with, an actual injury traceable to the defendant and likely to be redressed by a 8 favorable judicial decision.’” Spencer v. Kemna, 523 U.S. 1, 7 (1998) (quoting Lewis, 494 U.S. 9 at 477). 10 In the petition, Petitioner requested release from ICE custody. (ECF No. 1 at 10.) Per 11 Respondents’ notice, Petitioner has been removed to India, and counsel for Petitioner has not 12 filed any response to the notice disputing Petitioner’s removal. As Petitioner is no longer in ICE 13 custody, the Court finds that no case or controversy exists and the petition is moot. See Abdala v. 14 I.N.S., 488 F.3d 1061, 1065 (9th Cir. 2007) (holding habeas petition challenging length of 15 immigration detention was moot because “there was no extant controversy for the district court 16 to act upon” when petitioner was subsequently deported, “thereby curing his complaints about 17 the length of his INS detention”). 18 III. 19 RECOMMENDATION & ORDER 20 Accordingly, the Court HEREBY RECOMMENDS that the petition for writ of habeas 21 corpus be DISMISSED as moot. 22 Further, the Clerk of Court is DIRECTED to randomly assign this action to a District 23 Judge. 24 This Findings and Recommendation is submitted to the assigned United States District 25 Court Judge, pursuant to the provisions of 28 U.S.C. § 636 (b)(1)(B) and Rule 304 of the Local 26 Rules of Practice for the United States District Court, Eastern District of California. Within 27 FOURTEEN (14) days after service of the Findings and Recommendation, any party may file 1 | exhibits. Such a document should be captioned “Objections to Magistrate Judge’s Findings and 2 | Recommendation.” Replies to the objections shall be served and filed within fourteen (14) days 3 | after service of the objections. The assigned District Judge will then review the Magistrate 4 | Judge’s ruling pursuant to 28 U.S.C. § 636(b)(1)(C). The parties are advised that failure to file 5 | objections within the specified time may waive the right to appeal the District Court’s order. 6 | Wilkerson v. Wheeler, 772 F.3d 834, 839 (9th Cir. 2014) (citing Baxter v. Sullivan, 923 F.2d 7 | 1391, 1394 (9th Cir. 1991)). 8 9 10 IT IS SO ORDERED. FA. Se 11 | Dated: _ December 8, 2025 STANLEY A. BOONE 12 United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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2 3 4 5 6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8

9 MANDEEP SINGH SANDHU, Case No. 1:25-cv-00972-SAB-HC

10 Petitioner, FINDINGS AND RECOMMENDATION TO DISMISS PETITION FOR WRIT OF 11 v. HABEAS CORPUS AS MOOT

12 MINGA WOFFORD, et al., ORDER DIRECTING CLERK OF COURT TO RANDOMLY ASSIGN DISTRICT 13 Respondents. JUDGE

14 15 Petitioner, represented by counsel, is proceeding pro se with a petition for writ of habeas 16 corpus pursuant to 28 U.S.C. § 2241. 17 I. 18 BACKGROUND 19 On August 5, 2025, Petitioner filed the instant petition for writ of habeas corpus. (ECF 20 No. 1). Petitioner alleged that he has been detained by U.S. Immigration and Customs 21 Enforcement (“ICE”) beyond the removal period authorized by law, in violation of the Fifth 22 Amendment, 8 U.S.C. § 1231(a)(6), and implementing regulations. (ECF No. 1 at 8–9.1) 23 Petitioner requested release from custody. (Id. at 10.) On October 7, 2025, Respondents filed a 24 response, and on October 21, 2025, Petitioner filed a reply. (ECF Nos. 13, 14.) On November 20, 25 2025, Respondents filed a notice, which states: “According to Immigration and Customs 26 Enforcement, Mr. Sandhu has been deported to India. Given that, it appears this matter is now 27 mooted.” (ECF No. 20.) 1 II. 2 DISCUSSION 3 Article III of the United States Constitution limits the jurisdiction of federal courts to 4 “actual, ongoing cases or controversies.” Lewis v. Continental Bank Corp., 494 U.S. 472, 477 5 (1990). “This case-or-controversy requirement subsists through all stages of federal judicial 6 proceedings,” which “means that, throughout the litigation, the plaintiff ‘must have suffered, or 7 be threatened with, an actual injury traceable to the defendant and likely to be redressed by a 8 favorable judicial decision.’” Spencer v. Kemna, 523 U.S. 1, 7 (1998) (quoting Lewis, 494 U.S. 9 at 477). 10 In the petition, Petitioner requested release from ICE custody. (ECF No. 1 at 10.) Per 11 Respondents’ notice, Petitioner has been removed to India, and counsel for Petitioner has not 12 filed any response to the notice disputing Petitioner’s removal. As Petitioner is no longer in ICE 13 custody, the Court finds that no case or controversy exists and the petition is moot. See Abdala v. 14 I.N.S., 488 F.3d 1061, 1065 (9th Cir. 2007) (holding habeas petition challenging length of 15 immigration detention was moot because “there was no extant controversy for the district court 16 to act upon” when petitioner was subsequently deported, “thereby curing his complaints about 17 the length of his INS detention”). 18 III. 19 RECOMMENDATION & ORDER 20 Accordingly, the Court HEREBY RECOMMENDS that the petition for writ of habeas 21 corpus be DISMISSED as moot. 22 Further, the Clerk of Court is DIRECTED to randomly assign this action to a District 23 Judge. 24 This Findings and Recommendation is submitted to the assigned United States District 25 Court Judge, pursuant to the provisions of 28 U.S.C. § 636 (b)(1)(B) and Rule 304 of the Local 26 Rules of Practice for the United States District Court, Eastern District of California. Within 27 FOURTEEN (14) days after service of the Findings and Recommendation, any party may file 1 | exhibits. Such a document should be captioned “Objections to Magistrate Judge’s Findings and 2 | Recommendation.” Replies to the objections shall be served and filed within fourteen (14) days 3 | after service of the objections. The assigned District Judge will then review the Magistrate 4 | Judge’s ruling pursuant to 28 U.S.C. § 636(b)(1)(C). The parties are advised that failure to file 5 | objections within the specified time may waive the right to appeal the District Court’s order. 6 | Wilkerson v. Wheeler, 772 F.3d 834, 839 (9th Cir. 2014) (citing Baxter v. Sullivan, 923 F.2d 7 | 1391, 1394 (9th Cir. 1991)). 8 9 10 IT IS SO ORDERED. FA. Se 11 | Dated: _ December 8, 2025 STANLEY A. BOONE 12 United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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