Parveen Kumar v. Christopher Chestnut, et al.

CourtDistrict Court, E.D. California
DecidedFebruary 10, 2026
Docket1:26-cv-00669
StatusUnknown

This text of Parveen Kumar v. Christopher Chestnut, et al. (Parveen Kumar v. Christopher Chestnut, 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
Parveen Kumar v. Christopher Chestnut, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 PARVEEN KUMAR, Case No. 1:26-cv-00669-JLT-SKO (HC)

12 Petitioner, ORDER CONVERTING THE MATTER TO A PRELIMINARY INJUNCTION1; GRANTING 13 v. THE PRELIMINARY INJUNCTION IN PART; AND REFERRING THE MATTER TO 14 CRHISTOPHER CHESTNUT, et al., THE ASSIGNED MAGISTRATE

15 Respondents. (Doc. 2) 16 I. INTRODUCTION 17 Before the Court is Parveen Kumar’s request for a temporary restraining order (Doc. 2), 18 filed in conjunction with his petition for a writ of habeas corpus brought under 28 U.S.C. § 2241 19 challenging his ongoing detention. (Doc. 1.) Having evaluated the TRO request and 20 Respondents’ opposition (Doc. 8), the Court converts the matter into a motion for preliminary 21 injunction, GRANTS that motion IN PART, and REFERS the matter to the assigned magistrate 22 judge for a determination on the merits. 23 II. FACTUAL & PROCEDURAL BACKGROUND 24 Petitioner is a 27-year-old citizen of India who entered the United States without 25 inspection on or about August 27, 2024 where he was encountered by the Department of 26 Homeland Security. (Doc. 2 at 7.) Petitioner was released from initial border custody on April 27

28 1 The parties agreed that the motion for temporary restraining order could be converted to a preliminary 1 30, 2024 and was subject to certain supervision requirements, including electronic monitoring 2 and daily SmartLINK photo uploads. (Id.) Petitioner completed his first ICE check-in on May 3 13, 2024, and Immigration and Customs Enforcement installed a GPS wrist-style monitoring 4 device and an application on Petitioner’s phone on May 14, 2024. (Id.) Petitioner asserts that he 5 appeared for all Immigration Court hearings, complied with all ICE check-ins, has no criminal 6 history, and timely filed his Form 1-589 asylum application on May 17, 2024. (Id.) His removal 7 proceedings remain pending before the Concord Immigration Court, with an individual hearing 8 scheduled for June 1, 2026. (Id.) 9 Since arriving in the United States, Petitioner has continuously resided in Turlock, 10 California, where he received employment authorization and holds a valid Employment 11 Authorization Document valid from November 13, 2024 through November 12, 2029. (Id.) In 12 January 2025, Petitioner passed his commercial driving license exam and requested permission 13 from ICE to travel and work as a commercial truck driver in all 48 states. (Id.) Between February 14 20 and February 28, 2025, ICE granted this permission. (Id.) Petitioner also maintained strong 15 community ties through the Sikh Temple Turlock, where he regularly attended Sunday services, 16 volunteered with cleaning and landscaping, and served Langar to the congregation. (Id.) 17 On January 2, 2026, Petitioner received a text message from instructing him to report to 18 ICE on January 5, 2026. (Id. at 8.) At that time, he was in Minnesota for work as a commercial 19 truck driver. (Id. at 8.) He replied to the message stating that he could appear on January 6, 2026, 20 because he was not in California. (Id. at 8.) On January 6, 2026, Petitioner reported to the 21 Stockton ICE office as he had communicated but was taken into custody upon arrival. (Id. at 8.) 22 ICE officers informed him that the grounds for his arrest were a missed a virtual office visit 23 scheduled in October 2025 and low battery levels on his monitoring device. (Id. at 8.) Petitioner 24 explained to the officers that he was in another state traveling for work as a commercial truck 25 driver. (Id. at 8.) Petitioner is currently held at the California City Detention Center in California 26 City, California. 27 The government opposes the issuance of preliminary injunctive relief and maintains that 28 Petitioner’s detention is “mandatory” under expedited removal procedures set forth at 8 U.S.C. 1 § 1225(b)(2). (See generally Doc. 8.) 2 III. LEGAL STANDARD 3 The standard governing the issuing of a TRO is “substantially identical” to the standard 4 for issuing a preliminary injunction. See Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 5 F.3d 832, 839 n. 7 (9th Cir. 2001). A party seeking a preliminary injunction must establish: (1) 6 they are “likely to succeed on the merits” of their claims, (2) they are “likely to suffer irreparable 7 harm in the absence of a preliminary injunction,” (3) “the balance of equities tips in [their] 8 favor” and (4) “an injunction is in the public interest.” Winter v. Nat. Res. Def. Council, Inc., 555 9 U.S. 7, 20 (2008); see also Ctr. For Food Safety v. Vilsack, 636 F.3d 1166, 1172 (9th Cir. 2011) 10 (“After Winter, ‘plaintiffs must establish that irreparable harm is likely, not just possible, in 11 order to obtain a preliminary injunction.’”). 12 The party seeking a preliminary injunction has the burden to “make a showing on all four 13 prongs” of the Winter test to obtain a preliminary injunction. Alliance for the Wild Rockies v. 14 Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011); Mazurek v. Armstrong, 520 U.S. 968, 972 (1997) 15 (holding that the moving party has “the burden of persuasion”); see also Hecox v. Little, 104 16 F.4th 1061, 1073 (9th Cir. 2023). The Court may weigh the request for a preliminary injunction 17 with a sliding-scale approach. Alliance, at 1135 (9th Cir. 2011). Accordingly, a stronger showing 18 on the balance of hardships may support the issuance of a preliminary injunction where there are 19 “serious questions on the merits … so long as the plaintiff also shows that there is a likelihood of 20 irreparable injury, and that the injunction is in the public interest.” Id. Finally, “a preliminary 21 injunction is an extraordinary remedy never awarded as of right.” Winter, 555 U.S. at 24. 22 IV. ANALYSIS 23 A. Likelihood of Success on the Merits 24 This first factor “is the most important” under Winter, and “is especially important when 25 a plaintiff alleges a constitutional violation and injury.” Baird v. Bonta, 81 F.4th 1036, 1041 (9th 26 Cir. 2023). Petitioner argues he is likely to succeed on his claim that Respondents violated his 27 Fifth Amendment Due Process rights when he was detained without notice or provided a custody 28 hearing before a neutral arbiter. (Doc. 2 at 13-21.) 1 The Fifth Amendment Due Process Clause prohibits government deprivation of an 2 individual’s life, liberty, or property without due process of law. Hernandez v. Session, 872 F.3d 3 976, 990 (9th Cir. 2017). The Due Process Clause applies to all “persons” within the borders of 4 the United States, regardless of immigration status. Zadvydas v. Davis, 533 U.S. 678, 693 (2001) 5 (“[T]he Due Process Clause applies to all “persons” within the United States, including 6 noncitizens, whether their presence here is lawful, unlawful, temporary, or permanent.”). These 7 due process rights extend to immigration proceedings. Id. at 693–94. “Even when the 8 government has discretion to detain an individual, its subsequent decision to release the 9 individual creates ‘an implicit promise’ that she will be re-detained only if she violates the 10 conditions of her release.” Garro Pinchi v. Noem, No. 25-CV-05632-PCP, --- F. Supp. 3d. ----, 11 2025 WL 3691938, at *30 (N.D. Cal. Dec. 19, 2025) (citing Morrissey v. Brewer, 408 U.S. 471

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Parveen Kumar v. Christopher Chestnut, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/parveen-kumar-v-christopher-chestnut-et-al-caed-2026.