United States v. Abdumalikov

CourtDistrict Court, W.D. Washington
DecidedSeptember 20, 2024
Docket3:24-cv-05786
StatusUnknown

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

Bluebook
United States v. Abdumalikov, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 UNITED STATES OF AMERICA, CASE NO. 3:24-cv-05786-DGE 11 Plaintiff, ORDER GRANTING MOTION 12 v. FOR TEMPORARY RESTRAINING ORDER (DKT. NO. 2) 13 SHOHJAHONMIRZO ABDULMALIKOV, 14 Defendant. 15 16 The United States Department of Homeland Security, Immigration and Customs 17 Enforcement (hereinafter “ICE”), by and through the United States Attorney for the Western 18 District of Washington, has filed an ex parte emergency motion for a temporary restraining order 19 (“TRO”) permitting the Government to immediately perform involuntary medical monitoring, 20 testing, and physical examinations, as well as the administration of involuntary hydration 21 intravenously and nutrition via nasogastric tube, for Shohjahonmirzo Abdumalikov, who is 22 currently being held as a civil detainee at the Northwest ICE Processing Center (“NWIPC”) in 23 Tacoma, Washington. 24 1 Abdumalikov is a citizen and national of Uzbekistan. (Dkt. No. 5 at 3.) Abdumalikov 2 has been in ICE custody since September 3, 2023. (Id.) He was transferred to the NWIPC on 3 August 8, 2024 and remains there. (Id.) Abdumalikov was ordered removed to Uzbekistan on 4 June 28, 2024. (Id.) He has appealed that decision and the appeal remains pending. (Id.)

5 On July 25, 2024, Abdumalikov missed his ninth consecutive meal and was officially 6 listed by ICE as being on a hunger strike. (Id.) As of breakfast on September 19, 2024, he has 7 missed 179 meals and has consumed minimal food. (Dkt. No. 6 at 4.) Abdumalikov weighed 8 143 pounds at the beginning of his hunger strike. (Id. at 6.) As of September 2, 2024, he 9 weighed 122 pounds and had dropped 14.7% of his body weight. (Id.) Since September 3, 2024, 10 Abdumalikov has declined any medical assessment, has taken minimal nutrients and has had 11 decreasing fluid intake. (Id.) ICE medical staff has counseled Abdumalikov on the effects of his 12 hunger strike on his body. (Id. at 4.) Staff also has informed him of ICE’s intent to pursue 13 involuntary hydration and feeding to prevent injury and/or death if he continues his hunger 14 strike. (Id.)

15 ICE’s medical expert opines Abdumalikov’s body will begin to suffer significant damage 16 noting that it is difficult to predict how long Abdumalikov can survive without appropriate 17 sustenance. (Id. at 6.) The expert opines Abdumalikov’s health will continue to decline, noting 18 that, “[m]edical literature reflects that metabolic imbalance, caused by fasting, is likely to result 19 in permanent bodily damage and/or death once weight loss reaches 18% of a patient’s initial 20 weight.” (Id.) The expert opines Abdumalikov “will reach the point where he will require 21 immediate medical intervention to prevent further deterioration and serious medical 22 complications” if he continues with his hunger strike. (Id. at 7.) The expert further opines, “The 23 issuance of a court order to perform involuntary blood draws, collecting urine samples, all

24 1 necessary physical examinations, initiation of IV hydration, and involuntary [nasogastric] 2 feeding is medically necessary to preserve and sustain Abdumalikov’s health, welfare, medical 3 safety, and life.” (Id. at 8.) 4 The Government requests immediate authority to evaluate and care for Abdumalikov’s

5 health as requested by ICE’s medical expert. It appears the Government has caused to be served 6 the motion for temporary restraining order and supporting documents (presumably with the 7 summons and complaint) on Abdumalikov. (Dkt. No. 7 at 14.) 8 A plaintiff seeking a temporary restraining order must show: (1) they are likely to 9 succeed on the merits, (2) the potential for irreparable harm in the absence of preliminary relief, 10 (3) the balance of equities is in favor of injunction, and (4) the relief sought is in the public 11 interest. Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). Alternatively, a plaintiff 12 may obtain relief if they (1) demonstrate a serious question going to the merits has been raised; 13 (2) the balance of hardships tips sharply in plaintiff’s favor; (3) irreparable harms is likely to 14 occur; and (4) relief is in the public interest. Alliance for the Wild Rockies v. Cottrell, 632 F.3d

15 1127, 1134–1135 (9th Cir. 2021). 16 Temporary restraining orders “should be restricted to serving their underlying purpose of 17 preserving the status quo and preventing irreparable harm just so long as is necessary to hold a 18 hearing, and no longer.” Granny Goose Foods, Inc. v. Bhd. Of Teamsters and Auto Truck 19 Drivers Loc. No. 70 of Alameda Cty., 415 U.S. 423, 439 (1974). TROs can be mandatory in that 20 they can order a party to perform an affirmative act or a specific course of conduct. State of 21 Alabama v. United States, 304 F.2d 583, 590 (5th Cir. 1962), aff’d sub nom. Alabama v. United 22 States, 371 U.S. 37 (1962) (“Mandatory injunctions affirmatively compelling the doing of some 23 act, rather than merely negatively forbidding continuation of a course of conduct, are a

24 1 traditional tool of equity.”). Irreparable harm, as TROs seek to prevent, are injuries “for which 2 there is no adequate legal remedy.” See Nat’l Ass’n of Manufacturers v. United States Dep’t of 3 Homeland Sec., 491 F. Supp. 3d 549, 569 (N.D. Cal. 2020) (citing East Bay Sanctuary Covenant 4 v. Trump, 950 F.3d 1242, 1279 (9th Cir. 2020)).

5 At present, the Court does not have the benefit of any legal argument from Abdumalikov 6 identifying his position on whether the Government’s request for a temporary restraining order is 7 authorized. Assuming Abdumalikov opposes the Government’s motion, the Court acknowledges 8 there may exist differences of opinion as to what standard should be applied when evaluating the 9 constitutionality of administering involuntary medical care, hydration, and nutrition to civil 10 immigration detainees. See In re Bahadur, 441 F.Supp.3d 467, 475 (W.D. Tex. 2020) 11 (discussing possible standards under Turner v. Safley, 482 U.S. 78 (1987), Youngberg v. Romeo, 12 457 U.S. 307 (1982), and Bell v. Wolfish, 441 U.S. 520 (1979)). 13 Notwithstanding, 8 U.S.C. § 1231(f) authorizes the Attorney General, through ICE, to 14 provide necessary medical treatment to non-citizens in removal proceedings. See 8 U.S.C. §

15 1231(f). And, at least one district court has found Youngberg’s standard is the correct one to 16 apply in matters involving immigration detainees. See In re Kumar, 402 F. Supp. 3d 377, 383 17 (W.D. Tex. 2019). Kumar concluded the state’s interest in preventing the death of an 18 immigration detainee outweighed the detainee’s liberty interest in conveying a message through 19 a hunger strike or in directing their own medical care. 402 F. Supp. 3d at 384–385 (while in 20 immigration custody, “his [liberty] interest is diminished as his chosen avenue of conveying his 21 message, suicide by starvation, is not a liberty interest protected under the Constitution”). 22 Kumar granted the request to involuntary provide medical care and feeding to the detainee. Id. at 23 387.

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Related

Alabama v. United States
371 U.S. 37 (Supreme Court, 1962)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Youngberg v. Romeo Ex Rel. Romeo
457 U.S. 307 (Supreme Court, 1982)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Barton v. Clancy
632 F.3d 9 (First Circuit, 2011)
State of Alabama v. United States
304 F.2d 583 (Fifth Circuit, 1962)

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United States v. Abdumalikov, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-abdumalikov-wawd-2024.