Shah Mahmood Mirzada v. Warden, California City ICE Facility, et al.

CourtDistrict Court, E.D. California
DecidedJune 29, 2026
Docket1:26-cv-00425
StatusUnknown

This text of Shah Mahmood Mirzada v. Warden, California City ICE Facility, et al. (Shah Mahmood Mirzada v. Warden, California City ICE Facility, 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
Shah Mahmood Mirzada v. Warden, California City ICE Facility, 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 SHAH MAHMOOD MIRZADA, ) Case No.: 1:26-cv-00425-JLT-FJS (HC) A-Number: 249-374-607 ) 12 ) Petitioner, ) FINDINGS AND RECOMMENDATION TO 13 ) GRANT PETITION FOR WRIT OF HABEAS v. ) CORPUS 14 ) 15 WARDEN, CALIFORNIA CITY ICE ) [14-DAY DEADLINE] FACILITY, et al., ) 16 ) Respondents. ) 17 ) ) 18 ) 19 20 Petitioner is a pro se immigration detainee petitioning for writ of habeas corpus pursuant to 28 21 U.S.C. § 2241. 22 Petitioner filed the instant petition on January 20, 2026. (Doc. 1.) On February 20, 2026, 23 Respondent filed a combined motion to dismiss and response to the petition. (Doc. 8.) Petitioner did 24 not file a traverse. 25 Petitioner challenges his continued detention by the Bureau of Immigration and Customs 26 Enforcement (“ICE”). He claims his prolonged detention without a bond hearing violates his 27 procedural due process rights under the Fifth Amendment. He claims he should be immediately 28 1 released or, alternatively, provided a bond hearing before an immigration judge where the government 2 must justify his continued detention by clear and convincing evidence. 3 For the reasons discussed below, the court recommends the petition be granted in part and 4 Respondents be directed to provide Petitioner with a bond hearing before an immigration judge. 5 I. BACKGROUND 6 Petitioner is a native and citizen of Afghanistan who entered the United States under the CBP 7 One program on March 17, 2024. (ECF No. 8-1 at 2.) He was subsequently placed in ICE custody and 8 charged with removability under Immigration and Nationality Act (“INA”) § 212(a)(7)(A)(i)(I) for 9 lack of valid entry documents. (Id., at 6.) 10 In June 2024, Petitioner appeared before an immigration judge and conceded removability. (Id. 11 at 6.) In October 2024, he applied for asylum, withholding of removal, and protection under the 12 Convention Against Torture (“Convention”). (Id., at 7.) In September 2025, the immigration judge 13 issued a decision denying Petitioner’s application for asylum and withholding of removal but granting 14 his request for deferral of removal under the Convention. (ECF No. 8-1 at 6-21.) Petitioner appealed 15 the decision to the Board of Immigration Appeals (“Board”), and the appeal remains pending. (Id., at 16 24.) 17 Petitioner has remained in ICE custody since March 17, 2024, a period of over two years. 18 II. DISCUSSION 19 A. Jurisdiction 20 A district court may grant a writ of habeas corpus when the petitioner “is in custody in 21 violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c)(3). 22 “[D]istrict courts retain jurisdiction under 28 U.S.C. § 2241 to consider habeas challenges to 23 immigration detention that are sufficiently independent of the merits of [a] removal order.” Lopez- 24 Marroquin v. Barr, 955 F.3d 759, 759 (9th Cir. 2020) (citing Singh v. Holder, 638 F.3d 1196, 1211– 25 12 (9th Cir. 2011)). Pertinent here, the Supreme Court specifically directed that federal courts have 26 jurisdiction to review a constitutional challenge to a non-citizen’s detention. See Demore v. Kim, 538 27 U.S. 510, 517 (2003). 28 1 B. Mandatory Detention under 8 U.S.C. § 1225(b) 2 The parties acknowledge that Petitioner has been in continuous detention since March 17, 3 2024. Petitioner complains that the two-year period has become prolonged and indefinite and argues 4 that he should be given a bond hearing or, in the alternative, released from custody. 5 1. Statutory Background 6 A non-citizen who is present in the United States but has not been admitted is considered an 7 applicant for admission. 8 U.S.C.A. § 1225(a)(1). Such an applicant is subject to expedited removal if 8 the applicant (1) is inadmissible because he or she lacks a valid entry document; (2) has not “been 9 physically present in the United States continuously for the 2-year period immediately prior to the date 10 of the determination of inadmissibility”; and (3) is among those whom the Secretary of Homeland 11 Security has designated for expedited removal. 8 U.S.C. §§ 1225(b)(1)(A)(i), (iii)(I)–(II). Once “an 12 immigration officer determines” that a designated applicant “is inadmissible,” “the officer [must] 13 order the alien removed from the United States without further hearing or review.” 8 U.S.C.A. 14 § 1225(b)(1)(A)(i). Here, Petitioner was charged with removability for lacking valid entry documents. 15 If an applicant “indicates either an intention to apply for asylum” or “a fear of persecution,” the 16 immigration officer “shall refer the alien for an interview by an asylum officer.” 8 U.S.C.A. 17 §§ 1225(b)(1)(A)(i)–(ii). The point of this screening interview is to determine whether the applicant 18 has a “credible fear of persecution.” Id. § 1225(b)(1)(B)(v). If the asylum officer finds an applicant's 19 asserted fear to be credible, the applicant will receive “full consideration” of his asylum claim in a 20 standard removal hearing. 8 C.F.R. § 208.30(f); see 8 U.S.C. § 1225(b)(1)(B)(ii). If the asylum officer 21 finds that the applicant does not have a credible fear, a supervisor will review the asylum officer's 22 determination. 8 C.F.R. § 208.30(e)(8). If the supervisor agrees with the officer’s determination, the 23 applicant may appeal to an immigration judge, who can take further evidence and “shall make a de 24 novo determination.” Id. §§ 1003.42(c), (d)(1); see id. § 1225(b)(1)(B)(iii)(III). In this case, Petitioner 25 made a claim for asylum. The immigration judge denied the applications for asylum and withholding 26 but granted deferral of removal under the Convention. The matter is currently pending appeal with the 27 Board. 28 Regardless of whether applicants receive full or expedited review, they are not entitled to 1 “shall be detained pending a final determination of credible fear of persecution and, if found not to 2 have such a fear, until removed.” Id. (citing 8 U.S.C.A. § 1225(b)(1)(B)(iii)(IV)). Likewise, applicants 3 who are found to have a credible fear may also be detained pending further consideration of their 4 asylum applications. Id. (citing 8 U.S.C.A. § 1225(b)(1)(B)(ii)). In either case, the applicant must be 5 detained until the conclusion of those proceedings. Jennings v. Rodriguez, 583 U.S. 281, 297 (2018). 6 Nonetheless, an applicant “may be temporarily released on parole ‘for urgent humanitarian reasons or 7 significant public benefit.’” Id. at 288 (quoting 8 U.S.C. § 1182(d)(5)(A) and citing 8 C.F.R 8 §§ 212.5(b), 235.3 (2017)). Said parole request is considered by designated ICE Enforcement 9 Removal Operations (“ERO”) officers. 8 C.F.R.

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Bluebook (online)
Shah Mahmood Mirzada v. Warden, California City ICE Facility, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/shah-mahmood-mirzada-v-warden-california-city-ice-facility-et-al-caed-2026.