Vardan K. v. Warden of the California City Detention Center

CourtDistrict Court, E.D. California
DecidedMarch 16, 2026
Docket1:26-cv-01128
StatusUnknown

This text of Vardan K. v. Warden of the California City Detention Center (Vardan K. v. Warden of the California City Detention Center) 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
Vardan K. v. Warden of the California City Detention Center, (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 VARDAN K.,

11 No. 1:26-cv-01128-TLN-CSK Petitioner, 12 A # 027-667-681 13 v. 14 WARDEN OF THE CALIFORNIA CITY ORDER DETENTION CENTER, 15 Respondent. 16 17 This matter is before the Court on Petitioner Vardan K.’s (“Petitioner”) pro se1 Motion for 18 Temporary Restraining Order (“TRO”).2 (ECF No. 1.) Respondent filed a response. (ECF No. 19 7.) Petitioner filed a reply. (ECF No. 12.) For the reasons set forth below, Petitioner’s motion 20 for TRO is GRANTED3 and Respondent is ORDERED TO SHOW CAUSE why this Court 21 should not grant Petitioner’s habeas petition and enter judgment in favor of Petitioner. 22 /// 23 1 Since Petitioner’s initial filing of his motion for TRO, the Court appointed counsel who is 24 now enrolled in this case and has filed briefs on behalf of Petitioner. (ECF Nos. 6, 8, 12.)

25 2 As stated in the Court’s February 13, 2026 Order, the Court construes Petitioner’s pleading as a motion for a TRO based on the substance of the brief and the relief requested 26 therein. (ECF No. 6 at 1.) 27 3 On March 13, 2026, the Court issued a minute order granting Petitioner’s motion for TRO 28 and ordering his immediate release. (ECF No. 13.) This Order explains the Court’s reasoning. 1 I. FACTUAL BACKGROUND 2 The instant action arises from Petitioner’s allegedly unlawful detention. (See ECF No. 1.) 3 Petitioner asserts that he came to the United States as a refugee from the U.S.S.R. in 1986 when 4 he was twelve years old. (Id. at 2.) On May 25, 1999, an immigration judge ordered Petitioner 5 removed. (ECF No. 7-1 at 4.) Sometime in 1999, Petitioner was released from immigration 6 custody. (ECF No. 12 at 3.) Since then, Petitioner has checked in with U.S. Immigration and 7 Customs Enforcement (“ICE”) every year for the past 26 years. (ECF No. 1 at 2.) Petitioner was 8 re-detained by immigration officials when he reported to the immigration office on December 29, 9 2025. (ECF No. 7-1 at 2.) 10 On February 2, 2026, Petitioner filed a petition for writ of habeas corpus and motion for 11 TRO. (ECF No. 1.) Petitioner challenges his detention as violating his due process rights and 12 seeks immediate release. (Id. at 13–19.) On February 13, 2026, this Court directed Respondent 13 to file a response to Petitioner’s motion. (ECF No. 6.) On February 20, 2026, Respondent filed a 14 response. (ECF No. 7.) On March 5, 2026, Petitioner filed a reply. (ECF No. 12.) 15 II. STANDARD OF LAW 16 For a TRO to issue, courts consider whether Petitioner has established “[1] that he is 17 likely to succeed on the merits, [2] that he is likely to suffer irreparable harm in the absence of 18 preliminary relief, [3] that the balance of equities tips in his favor, and [4] that an injunction is in 19 the public interest.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). Petitioner 20 must “make a showing on all four prongs” of the Winter test. Alliance for the Wild Rockies v. 21 Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011). The Court may weigh Petitioner’s showing on 22 each of the Winter factors using a sliding-scale approach. Id. A stronger showing on the balance 23 of the hardships may support issuing a TRO even where there are “serious questions on the merits 24 . . . so long as the [petitioner] also shows that there is a likelihood of irreparable injury and that 25 the injunction is in the public interest.” Id. Simply put, if “serious questions going to the merits 26 were raised [then] the balance of hardships [must] tip[ ] sharply” in Petitioner’s favor in order to 27 succeed in a request for a TRO. Id. at 1134–35. 28 /// 1 III. ANALYSIS 2 The Court considers each of the Winter elements in turn. 3 A. Likelihood of Success on the Merits 4 Petitioner argues that his detention without a bond hearing violates his due process rights. 5 (ECF No. 1 at 13.) In opposition, Respondent claims Petitioner is detained under 8 U.S.C. § 6 1231(a)(6) (“§ 1231(a)(6)”), which authorizes ICE to detain non-citizens with final orders of 7 removal to effectuate deportation.4 (ECF No. 7 at 2–3.) Respondent argues Petitioner has not 8 even been detained for 60 days and is creating an obstacle to his removal by not assisting with 9 obtaining a travel document. (Id. at 3.) In reply, Petitioner asserts Respondent is incorrect to rely 10 on § 1231(a)(6) because it does not permit immigration officials to re-arrest and re-detain 11 released noncitizens without notice or process at any time after an order of removal has been final 12 for more than 90 days. (ECF No. 12 at 6.) Instead, Petitioner contends that because his final 13 order of removal “became final long ago,” the 90-day removal period has expired and he is 14 subject to supervision under § 1231(a)(3), not detention. (Id.) 15 The Fifth Amendment Due Process Clause prohibits government deprivation of an 16 individual’s life, liberty, or property without due process of law. Hernandez v. Sessions, 872 F.3d 17 976, 990 (9th Cir. 2017). The Due Process Clause applies to all “persons” within the borders of 18 the United States, regardless of immigration status. Zadvydas v. Davis, 533 U.S. 678, 693 (2001) 19 (“[T]he Due Process Clause applies to all ‘persons’ within the United States, including 20 [noncitizens], whether their presence here is lawful, unlawful, temporary, or permanent.”). These 21 due process rights extend to immigration proceedings, including deportation proceedings. Id. at 22 693–94; see Demore v. Kim, 538 U.S. 510, 523 (2003). 23 Courts examine procedural due process claims in two steps: the first asks whether there 24 exists a protected liberty interest under the Due Process Clause, and the second examines the 25 procedures necessary to ensure any deprivation of that protected liberty interest accords with the 26 4 Respondent also makes several arguments about the appropriate form of release available 27 in a habeas petition, whether the Court can enjoin Petitioner’s removal from the United States, and whether the Court lacks jurisdiction to enjoin removal to a third country. (ECF No. 7 at 5–7.) 28 The Court declines to address these arguments at this juncture. 1 Constitution. See Kentucky Dep’t of Corrections v. Thompson, 490 U.S. 454, 460 (1989); 2 Morrissey v. Brewer, 408 U.S. 471, 481 (1972) (“Once it is determined that due process applies, 3 the question remains what process is due.”). 4 i. Liberty Interest 5 “Freedom from imprisonment — from government custody, detention, or other forms of 6 physical restraint — lies at the heart of the liberty that [the Due Process] Clause protects.” 7 Zadvydas, 533 U.S. at 690. “Even individuals who face significant constraints on their liberty or 8 over whose liberty the government wields significant discretion retain a protected interest in their 9 liberty.” Pinchi v. Noem, 792 F. Supp. 3d 1025, 1032 (N.D. Cal. July 24, 2025). To determine 10 whether an individual’s specific conditional release rises to the level of a protected liberty 11 interest, courts have “compar[ed] the specific conditional release in the case before them with the 12 liberty interest in parole as characterized by Morrissey.” R.D.T.M. v. Wofford, No. 1:25-CV- 13 01141-KES-SKO, 2025 WL 2617255, at *3 (E.D. Cal. Sept. 9, 2025).

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Vardan K. v. Warden of the California City Detention Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vardan-k-v-warden-of-the-california-city-detention-center-caed-2026.