Pham v. Becerra

CourtDistrict Court, N.D. California
DecidedFebruary 15, 2024
Docket3:23-cv-01288
StatusUnknown

This text of Pham v. Becerra (Pham v. Becerra) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pham v. Becerra, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 HUNG PHI PHAM, Case No. 23-cv-01288-CRB

9 Plaintiff,

ORDER GRANTING PETITION 10 v. FOR WRIT OF HABEAS CORPUS

11 MOISES BECERRA, et al., 12 Defendants.

13 In March 2023, Petitioner Hung Phi Pham (Pham), was detained at Golden State 14 Annex pending removal proceedings pursuant to 8 U.S.C. § 1226(c), a federal mandatory 15 detention statute for aggravated felony convictions. The Government refused to provide 16 Pham with a bond hearing, so Pham filed a petition for writ of habeas corpus and a motion 17 for a temporary restraining order, arguing that due process entitled him to a bond hearing. 18 See Pet. (dkt. 1). This Court granted a temporary restraining order (TRO) enjoining the 19 Department of Homeland Security and Respondents from continuing to detain Pham 20 without a bond hearing. Order Granting TRO (dkt. 20). Thereafter, an Immigration Judge 21 (IJ) ordered Pham to be released on a minimum bond of $1500. See Stipulation (dkt. 23). 22 Following Pham’s posting of bond and release from custody, the Government filed 23 a return requesting that this Court dismiss Pham’s habeas petition. See Return (dkt. 27). 24 Pham then filed a traverse requesting that this Court affirm that a bond hearing was 25 required by due process under the Fifth Amendment and to permanently enjoin the 26 Government from detaining Pham without a bond hearing. See Traverse (dkt. 28). The 27 Court GRANTS Pham’s petition for habeas corpus and permanently enjoins Defendants 1 pre-date the Court’s order, for more than five days without a bond hearing, at which the 2 Government bears the burden of justifying Pham’s detention by clear and convincing 3 evidence. 4 I. BACKGROUND 5 A. Pham’s Background and Criminal Conviction 6 Pham was born in Vietnam and came to the United States on a nonimmigrant 7 student visa in 2008. Pham Decl. (dkt. 1-1) ¶¶ 1–3. In 2010, Pham became a lawful 8 permanent resident. Id. ¶ 5 9 In February 2013, while he was a student at University of California, Santa Cruz, 10 Pham sexually molested another student. See id. ¶ 8. Pham was convicted in Santa Clara 11 County Superior Court for violation of California Penal Code § 289(e) (Sexual Penetration 12 When the Victim was Intoxicated or Anesthetized) in March 2015 and sentenced to 364 13 days in county jail. Palakiko Decl. (dkt. 15-1) ¶¶ 6–7. Pham served six months in jail and 14 was released in August 2015. Pham Decl. ¶ 15. 15 Following his release, Pham completed three years of probation and registered as a 16 sex offender in California. Id. ¶¶ 18, 22. Due to the difficulty of pursuing a career as a 17 pharmacist—the career he had been attending school for—with a felony conviction, Pham 18 worked in construction for his uncle. Id. ¶¶ 13, 23. He completed rehabilitation and 19 alcohol abuse programs. Id. ¶ 18. In January 2020, he married, Han Nguyen Khanh 20 Duong (Duong), a U.S. citizen, and in August 2020, they had their first child together. Id. 21 ¶ 26. 22 B. Pham’s Naturalization 23 In June 2021, Pham applied for U.S. citizenship. Id. ¶ 27. On his naturalization 24 application, he included his current address and disclosed his conviction. Id. ¶ 28. In 25 April 2022, Pham appeared at the United States Citizenship and Immigration Services 26 (USCIS) office in Santa Clara for an interview in support of his naturalization application. 27 Id. There, the USCIS officer informed Pham that a decision was still pending on his 1 On January 19, 2023—nine months after Pham’s interview, more than a year and a 2 half after he submitted his naturalization application, and seven years after his release from 3 criminal custody—United States and Customs (ICE) officers removed Pham from his 4 home and took him into custody at a private detention facility. Id. ¶ 30. Duong, who 5 answered the door, was nine months pregnant with their second child. Id. Pham and 6 Duong’s second child was subsequently born while Pham remained in ICE detention. Id. ¶ 7 36. 8 C. Detention and TRO 9 Pham was detained at Golden State Annex, a private detention facility in 10 McFarland, California, pending his removal proceedings. Id. ¶ 30; Ballout Decl. (dkt. 1-3) 11 ¶ 5. In February 2023, an IJ determined that under 8 U.S.C. § 1226(c), Pham was not 12 entitled to a bond hearing. See Ballout Decl. ¶ 5. Pham appealed this determination. See 13 Palakiko Decl. Ex. H. On March 16, three months after Pham’s detention began, the IJ 14 sustained the charge of removability against Pham. Id. Pham thereafter filed a petition for 15 writ of habeas corpus and a motion for a TRO, arguing that due process entitled him to 16 bond hearing. See Pet. This Court granted the TRO on March 31, 2023, ordering the 17 Government to provide Pham with a bond hearing within five days, at which the 18 Government would bear the burden of proof. See TRO at 1. 19 D. Developments Since the TRO 20 On April 5, 2023, an IJ conducted a bond hearing and ordered Pham to be released 21 on a minimum bond in the amount of $1,500. See Stipulation (dkt. 23). ICE did not 22 appeal that bond order to the Board of Immigration of Appeals (BIA). See Suppl. Pham. 23 Decl. (dkt. 28) ¶ 2. The Court granted the parties’ stipulation to vacate the briefing 24 schedule for the preliminary injunction, set a briefing schedule for the underlying habeas 25 petition, and extended the temporary restraining order until the petition is adjudicated. Id. 26 The Government now reraises arguments that the Court considered and rejected in 27 the TRO order. II. JURISDICTION 1 Before the Court can address the merits of Pham’s habeas petition, the Court must 2 first consider whether this Court has habeas jurisdiction over the matter. Federal district 3 courts are limited to granting habeas relief “within their respective jurisdictions,” which 4 means that the district court must have jurisdiction over the plaintiff’s custodian. 28 5 U.S.C. § 2241(a); see Rumsfeld v. Padilla, 542 U.S. 426, 442 (2004). The Government 6 contends that under Rumsfeld v. Padilla’s district-of-confinement rule, this Court does not 7 have jurisdiction because Pham was detained in the Eastern District of California. The 8 Government also argues that even if the rule does not apply, the proper respondent and 9 custodian is similarly outside of this Court’s jurisdiction. The Court will first address why 10 Padilla’s district-of-confinement rule does not apply to this case and will next address why 11 Pham has named the proper respondent. 12 A. The District-of-Confinement Rule 13 In Padilla, the Supreme Court considered whether the Southern District of New 14 York had jurisdiction over a habeas petition brought by a U.S. citizen detained in military 15 custody in South Carolina. Padilla, 542 U.S. at 435. The Court held that the “default rule” 16 in habeas challenges to present physical confinement is the “district of confinement 17 rule”—that is, “the proper respondent is the warden of the facility where the prisoner is 18 being held.” Id. at 446. Applying that rule, the Court concluded that the proper 19 respondent in Padilla’s case was the commander of the naval brig who “exercis[ed] day-to- 20 day control over [his] custody.” Id. Because the commander of the naval brig was in 21 South Carolina, the Court concluded that the Southern District of New York did not have 22 jurisdiction over Padilla’s petition. 23 However, Padilla did not establish a bright-line district-of-confinement rule.

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Pham v. Becerra, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pham-v-becerra-cand-2024.