Manpreet Singh v. Warden, et al.

• Court: District Court, E.D. California
• Decided: February 24, 2026
• Docket: 1:26-cv-00197
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ----oo0oo---- 11 12 MANPREET SINGH, No. 1:26-cv-0197 WBS CSK 13 Petitioner, 14 v. MEMORANDUM AND ORDER DENYING PETITIONER’S MOTION FOR 15 WARDEN, et al., TEMPORARY RESTRAINING ORDER 16 Defendant. 17 18 ----oo0oo---- 19 Petitioner Manpreet Singh is an Indian national who 20 entered the United States unlawfully and without inspection on 21 August 6, 2024. (Docket No. 1 at 5.) He was then detained by 22 immigration officials and subsequently released on parole in 23 October 2024. (Id.) 24 Petitioner alleges he was re-detained upon a scheduled 25 visit to the Fresno Immigration and Customs Enforcement office on 26 November 21, 2025, and has been in custody since. (Id.) 27 Respondents have responded that “records maintained by 28 immigration authorities do not indicate any specific reason for 1 Singh’s re-detention” on that date. (Docket No. 11 at 1-2.) 2 On February 17, 2026, petitioner filed the instant 3 motion for a temporary restraining order, in which he requests 4 that he be released from detention. (Docket No. 9.) Petitioner 5 argues that his release is warranted because his “prolonged 6 detention,” which has been in effect for approximately two 7 months, violates the Due Process Clause. (See id. at 2-3.)1 8 The length of an individual’s detention, alone, is not 9 determinative of whether detention violates the Due Process 10 Clause.2 Determining whether prolonged immigration detention 11 violates the Due Process Clause requires consideration of 12 whether: (1) the petitioner's immigration proceedings have been 13 infected with bad faith or undue delay by the agency; (2) the 14 petitioner's detention is directly associated with a judicial 15 review process that has a definite and evidently impending 16 termination point, and is thus akin to detention during the 17 administrative review process that was upheld by the Supreme 18 Court; and (3) there is evidence that the petitioner is 19 unremovable because the destination country will not accept him 20 1 Petitioner does not argue that his release is required 21 by 8 U.S.C. § 1226. In a series of cases, this court has 22 explained why non-citizens like petitioner who entered the United States illegally are properly subject to mandatory detention 23 pursuant to 8 U.S.C. § 1225. See, e.g., Uulu v. Warden, --- F. Supp. 3d ----, 2026 WL 412204 (E.D. Cal. Feb. 13, 2026) 24 (collecting this court’s cases).

25 2 Even if the length of detention could, in and of itself, establish a violation of the Due Process Clause, 26 petitioner’s approximately two-month-long detention falls far 27 short of the six-month immigration detention period the Supreme Court held to be presumptively constitutional in Zadvydas v. 28 Davis, 533 U.S. 678 (2001). ee nnn en nn non nnn nn nn nen nn nen ne OI OD OE

1 or his removal is barred by our own laws. Uulu v. Warden, --- F. 2 Supp. 3d ----, 2026 WL 412204, at *7 (E.D. Cal. Feb. 13, 2026) 3 (citation modified). 4 Petitioner has not provided any evidence that his 5 “immigration proceedings have been infected with bad faith or 6 undue delay.” Uulu, 2026 WL 412204, at *7. Further, as 7 respondents point out, petitioner’s detention is “‘directly 8 associated with a judicial review process that has a definite and 9 evidently impending termination point,’ namely, asylum 10 | proceedings that he himself chose to initiate.” (Docket No. 11 11 at 4 (quoting Uulu, 2026 WL 412204, at *7).) Lastly, there is no 12 evidence that petitioner is unremovable for any reason or that 13 | his removal would be barred by our laws. See Uulu, 2026 WL 14 412204, at *7. 15 Accordingly, for the foregoing reasons and the reasons 16 set forth in Uulu, 2026 WL 412204, IT IS HEREBY ORDERED that 17 petitioner’s motion for temporary restraining order (Docket No. 18 9) be, and the same hereby is, DENIED. 19 Pursuant to 28 U.S.C. $ 636(b) (1) (B) and Local General 20 Order No. 262, this case is referred to the assigned magistrate 21 judge for further proceedings. 22 | Dated: February 24, 2026 he bloom HK Ld. 23 WILLIAM B. SHUBB UNITED STATES DISTRICT JUDGE

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