Marquez-Diaz v. Ripa

CourtDistrict Court, S.D. Florida
DecidedJuly 22, 2025
Docket1:25-cv-23256
StatusUnknown

This text of Marquez-Diaz v. Ripa (Marquez-Diaz v. Ripa) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marquez-Diaz v. Ripa, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 25-cv-23256-ALTMAN

ROBERTO MARQUEZ-DIAZ,

Petitioner,

v.

GARRETT RIPA, in his official capacity as Field Office Director, Florida Region, et al.,

Respondents. ___________________________________/

ORDER DENYING EMERGENCY REQUEST FOR TEMPORARY RESTRAINING ORDER

Our Petitioner, Roberto Marquez-Diaz, “is in federal immigration custody and is believed to be currently detained at ICE-ERO Center in Miramar, Florida.” Petition [ECF No. 1] at 1. The Petitioner believes that U.S. Immigration and Customs Enforcement (“ICE”) “will soon relocate Petitioner to the recently opened Everglades Detention Center or another facility outside of the state[,]” and that this “forthcoming relocation . . . will cause him and his family irreparable harm and violate his Fifth Amendment Right to Due Process and Sixth Amendment Right to Counsel.” Id. at 1–2. The Petitioner therefore wants us to issue “an emergency order to prevent the Respondents from moving him to another detention facility” outside the Southern District of Florida. Id. at 2. For the following reasons, we DENY this request for a temporary restraining order (“TRO”).1

1 While we deny the Petitioner’s request for a TRO on the merits, we recognize that this request— which was embedded within his petition for a writ of habeas corpus—is procedurally improper. See Hussain v. Hussain, 2022 WL 198811, at *1 (M.D. Fla. Jan. 12, 2022) (Howard, J.) (“[T]he Court struck the initial complaint and denied Plaintiffs’ embedded request for a temporary restraining order without prejudice to the filing of an appropriate motion.”); Guarantee Co. N. Am. USA v. Gadcon, Inc., 2009 WL 5062350, at *1 n.1 (S.D. Ala. Dec. 23, 2009) (Steele, J.) (“Rather than embedding a request for emergency injunctive relief in a pleading, a better practice would be to file separate motions for temporary restraining order and preliminary injunction contemporaneously with the Complaint.”); see also S.D. FLA. L.R. 7.1(a)(2) (requiring any request “seeking emergency or ex parte relief or a temporary THE LAW A temporary restraining order, unlike a preliminary injunction, “may be issued ‘without written or oral notice to the adverse party or its attorney[.]’” Finkelstein v. Mt. Sinai Med. Ctr. of Fla., 2023 WL 6118179, at *2 n.1 (S.D. Fla. Sept. 19, 2023) (Altman, J.) (quoting FED. R. CIV. P. 65(b)(1)). A TRO “is appropriate where the movant demonstrates that: (a) there is a substantial likelihood of success on the merits; (b) the TRO . . . is necessary to prevent irreparable injury; (c) the threatened injury

outweighs the harm that the TRO . . . would cause to the non-movant; and (d) the TRO . . . would not be averse to the public interest.” Parker v. State Bd. of Pardons and Paroles, 275 F.3d 1032, 1034–35 (11th Cir. 2001). Although a “showing of irreparable injury is the sine qua non of injunctive relief[,]” Siegel v. LePore, 234 F.3d 1163, 1176 (11th Cir. 2000) (en banc) (cleaned up), the movant “bears the ‘burden of persuasion’ to clearly establish all four of these prerequisites[,]” Wreal, LLC v. Amazon.com, Inc., 840 F.3d 1244, 1247 (11th Cir. 2016) (emphasis added) (citing Siegel, 234 F.3d at 1176); see also Finkelstein, 2023 WL 6118179, at *2 (“Still, a district court cannot grant a [TRO] unless the moving party satisfies all four of the requirements.”). The movant must also “clearly show that immediate and irreparable injury, loss, or damage will result to the movant before the adverse party can be heard in opposition[.]” FED. R. CIV. P. 65(b)(1)(A); see also Gentles-Daughtry v. Daughtry, 2016 WL 8678027, at *2 (S.D. Fla. Jan. 20, 2016) (Cohn, J.) (“Here, the Court will deny Plaintiff’s Motion because she has not sufficiently shown that she will suffer an irreparable injury unless the Court enters a temporary

restraining order without affording Defendant any opportunity to respond. . . . Plaintiff’s motion does not ‘convince [the] court that there is immediate and great danger of irreparable injury that necessitates the temporary dispensing of some of the trappings of due process.’” (quoting 11A CHARLES ALAN WRIGHT & ARTHUR R. MILLER, ET AL., FEDERAL PRACTICE AND PROCEDURE § 2952 (3d ed. 1998))).

restraining order” to be filed as a motion). In addition, despite labeling his request for a TRO as an “emergency,” the Petitioner hasn’t complied with any of our requirements for filing emergency motions. See generally S.D. FLA. L.R. 7.1(d)(1). ANALYSIS The Petitioner wants us to issue “a temporary restraining order that Petitioner shall not be transferred outside the Southern District of Florida until further notice from this Honorable Court[.]” Petition at 8. This request is intertwined with the Petition’s second ground for relief, which argues that relocation would violate the Petitioner’s Sixth Amendment rights “by obstructing counsel’s access to the Petitioner, impairing access to in-person confidential communication, frustrating the timely

submission of filings, and preventing Petitioner from meaningfully participating in his defense and in the pursuit of immigration relief.” Id. at 8.2 After careful review, we find that the Petitioner hasn’t met any of the four elements of a TRO. First, the Petitioner isn’t likely to succeed on his Sixth Amendment claim. As an initial matter, we doubt that the Petitioner has a Sixth Amendment right to counsel (although he may have the right to counsel under the Fifth Amendment). See Dakane v. U.S. Att’y Gen., 399 F.3d 1269, 1273 (11th Cir. 2005) (“It is well established in this Circuit that an alien in civil deportation proceedings, while not entitled to a Sixth Amendment right to counsel, has the constitutional right under the Fifth Amendment Due Process Clause right to a fundamentally fair hearing to effective assistance of counsel where counsel has been obtained.”); see also Sessions v. Dimaya, 584 U.S. 148, 226 n.6 (2018) (Thomas, J., dissenting) (“[T]he Sixth Amendment does not apply in immigration cases like this one.”). In any event, we don’t see how relocating the Petitioner to an ICE facility outside the Southern District of

Florida would violate his right to counsel (under either the Fifth or Sixth Amendments). The Petitioner claims that “[m]any ICE detention facilities do not have resources or facilities for confidential legal calls or videos visits” and that they “are in remote locations.” Petition at 8. But these “assertion[s]

2 In his other ground for relief, the Petitioner argues that “[d]etaining Petitioner and preparing to remove him—despite a grant of asylum, binding regulatory protections, and a pending administrative appeal violates the Due Process Clause of the Fifth Amendment.” Petition at 7 (cleaned up). Since this ground is unrelated to the proposed TRO (which concerns the Petitioner’s relocation to a new facility rather than his detention), it isn’t relevant to our decision today. [are] speculative . . . as Petitioner presents no evidence that he would have no, or effectively no, access to counsel in a different detention facility.” Guerra-Castro v. Parra, 2025 WL 1984300, at *3 (S.D. Fla. July 17, 2025) (Gayles, J.) And, as Judge Gayles explained, an “alien does not have the right to be detained in a facility that gives him preferred access to counsel.” Ibid. (citing Calla-Collado v. Att’y Gen.

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Marquez-Diaz v. Ripa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marquez-diaz-v-ripa-flsd-2025.