Miguel Chiguil Chiguil (A-242-441-617) v. Kristi Noem, et al.

CourtDistrict Court, E.D. California
DecidedApril 3, 2026
Docket1:26-cv-01844
StatusUnknown

This text of Miguel Chiguil Chiguil (A-242-441-617) v. Kristi Noem, et al. (Miguel Chiguil Chiguil (A-242-441-617) v. Kristi Noem, 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.

Bluebook
Miguel Chiguil Chiguil (A-242-441-617) v. Kristi Noem, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MIGUEL CHIGUIL CHIGUIL (A-242- No. 1:26-cv-1844 DAD CSK 441-617), 12 Petitioner, 13 FINDINGS AND RECOMMENDATIONS v. 14 KRISTI NOEM, et al., 15 Respondents. 16

17 18 Petitioner Miguel Chiguil Chiguil (A-242-441-617), a native and citizen of Guatemala, 19 who is proceeding through counsel, filed a verified petition for writ of habeas corpus pursuant to 20 28 U.S.C. § 2241.1 Petitioner entered the United States in March 2014. On or about October 21 2025, petitioner was arrested by U.S. Immigration and Customs Enforcement (“ICE”) officials 22 and has been in continuous detention since October 2025. This habeas action concerns 23 petitioner’s October 2025 detention. For the reasons that follow, the Court recommends granting 24 the petition for writ of habeas corpus. 25 /// 26 /// 27 1 This matter proceeds before the undersigned pursuant to 28 U.S.C. § 636, Fed. R. Civ. P. 72, 28 and Local Rule 302(c)(17). 1 I. FACTUAL BACKGROUND2 2 Petitioner is a native/citizen of Guatemala. (ECF No. 3 at 5.) Petitioner entered the 3 United States without inspection in March 2014. (Id. at 7.) Petitioner was “apprehended already 4 in the United States, released on his own recognizance, and later re-apprehended when he was 5 complying with mandatory inspection appointments.” (ECF No. 1 at 18; see also id. at 23; ECF 6 No. 11 at 2 (“Petitioner’s prior release in the discretion of DHS…).) In either September 2025 or 7 October 2025, petitioner was arrested by ICE officers and re-detained. (See ECF No. 1 at 7; ECF 8 No. 11 at 2.) On October 7, 2025, an immigration judge denied petitioner bond for lack of 9 jurisdiction pursuant to In re Matter of Yajure Hurtado, 29 I&N Dec. 216 (BIA 2025). (ECF No. 10 3 at 1.) On October 23, 2025, petitioner was issued a Notice to Appear in standard removal 11 proceedings pursuant to Immigration and Nationality Act (“INA”) Section 240 (8 U.S.C. 12 § 1229a).3 (Id. at 5.) In addition, the Notice to Appear does not allege petitioner is an “arriving 13 alien,” though the Notice does include a place to designate this information. (Id.) The Notice to 14 Appear charged petitioner with violating INA section 212(a)(6)(A)(i) (8 U.S.C. 15 § 1182(a)(6)(A)(i)) as a noncitizen who entered the United States without being admitted or 16 2 Petitioner filed a verified habeas petition. (ECF No. 1 at 32.) A court “may treat the 17 allegations of a verified . . . petition [for writ of habeas corpus] as an affidavit.” L. v. Lamarque, 351 F.3d 919, 924 (9th Cir. 2003) (citing McElyea v. Babbitt, 833 F.2d 196, 197-98 (9th Cir. 18 1987)). The record before the Court includes various discrepancies. First, respondents assert that 19 petitioner entered the United States in March 2024 (ECF No. 11 at 2), while petitioner alleges that he entered the United States in March 2014 (ECF No. 1 at 7), which is supported by the 20 government’s Notice to Appear that identifies petitioner’s entry as March 1, 2014 (ECF No. 3 at 5). Because the Court treats the verified petition as an affidavit and the petition’s allegations are 21 supported by the Notice to Appear, the Court finds that petitioner entered the United States in March 2014. Second, respondents assert that petitioner was arrested for driving a motor vehicle 22 without a license in September 2025 (ECF No. 11 at 2), and petitioner alleges that he has no 23 criminal history (ECF No. 1 at 7). The Court need not resolve this factual dispute where the government does not assert that petitioner is detained under 8 U.S.C. § 1226(c) on the basis of his 24 criminal history. Third, the record includes references to petitioner’s detention in both October 2025 and September 2025. (See ECF No. 1 at 7 (detained in “October, 2026 [sic],” typographical 25 error construed to be “October, 2025”); ECF No. 3 at 1 (immigration judge order dated October 7, 2025), 5 (Notice to Appear dated October 23, 2025); ECF No. 11 at 2 (detained on September 9, 26 2025).) This factual discrepancy need not be resolved as it does not affect the Court’s analysis. 27 3 Removal proceedings pursuant to 8 U.S.C. § 1229a (INA § 240) are standard removal proceedings, which are different from expedited removal proceedings pursuant to 8 U.S.C. 28 § 1225(b)(1) (INA § 235(b)(1)). 1 paroled, or who arrived in the United States at any time or place other than as designated by the 2 Attorney General. (Id.) On January 9, 2026, an immigration judge again denied petitioner bond 3 for lack of jurisdiction pursuant to In re Matter of Yajure Hurtado. (Id. at 3.) 4 II. PROCEDURAL BACKGROUND 5 On March 6, 2026, petitioner filed his petition for writ of habeas corpus. (ECF No. 1.) 6 On March 10, 2026, this Court ordered respondents to file a response to the petition within seven 7 days. (ECF No. 6.) After respondents failed to file a response to the petition within seven days, 8 on March 18, 2026 this Court granted respondents until 5:00 p.m. on March 18, 2026 to file a 9 response. (ECF No. 7.) This Court ordered that respondents’ failure to file a response would be 10 interpreted as a non-opposition to granting the petition. (Id.) Respondents did not file a response 11 to the petition by 5:00 p.m. March 18, 2026. See Docket. On March 24, 2026, petitioner 12 requested entry of default. (ECF No. 8.) On March 25, 2026, apparently in response to the 13 petitioner’s request for entry of default, respondents filed a motion for an extension of time to file 14 a response to the petition after realizing they had failed to respond to the petition and failed to 15 comply with the Court’s orders. (ECF No. 9.) The Court granted in part respondents’ request for 16 an extension and respondents filed their response on March 27, 2026. (ECF Nos. 10, 11.) 17 Petitioner filed an opposition on April 2, 2026. (ECF No. 12.) Briefing is now closed. 18 III. LEGAL STANDARD 19 The Constitution guarantees the availability of the writ of habeas corpus “to every 20 individual detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) 21 (citing U.S. Const., Art I, § 9, cl. 2). “The essence of habeas corpus is an attack by a person in 22 custody upon the legality of that custody, and . . . the traditional function of the writ is to secure 23 release from illegal custody.” Preiser v. Rodriguez, 411 U.S. 475, 484 (1973). A writ of habeas 24 corpus may be granted to a petitioner who demonstrates that he is in custody in violation of the 25 Constitution or federal law. 28 U.S.C. § 2241(c)(3). Historically, “the writ of habeas corpus has 26 served as a means of reviewing the legality of Executive detention, and it is in that context that its 27 protections have been strongest.” I.N.S. v. St.

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Bluebook (online)
Miguel Chiguil Chiguil (A-242-441-617) v. Kristi Noem, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-chiguil-chiguil-a-242-441-617-v-kristi-noem-et-al-caed-2026.