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

District Court, E.D. California·Decided March 16, 2026·No. 1:26-cv-01128·Unknown

Opinion

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

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 therein. (ECF No. 6 at 1.) 3 On March 13, 2026, the Court issued a minute order granting Petitioner’s motion for TRO and ordering his immediate release. (ECF No. 13.) This Order explains the Court’s reasoning. The instant action arises from Petitioner’s allegedly unlawful detention. (See ECF No. 1.) Petitioner asserts that he came to the United States as a refugee from the U.S.S.R. in 1986 when he was twelve years old. (Id. at 2.) On May 25, 1999, an immigration judge ordered Petitioner removed. (ECF No. 7-1 at 4.) Sometime in 1999, Petitioner was released from immigration custody. (ECF No. 12 at 3.) Since then, Petitioner has checked in with U.S. Immigration and Customs Enforcement (“ICE”) every year for the past 26 years. (ECF No. 1 at 2.) Petitioner was re-detained by immigration officials when he reported to the immigration office on December 29, 2025. (ECF No. 7-1 at 2.) On February 2, 2026, Petitioner filed a petition for writ of habeas corpus and motion for TRO. (ECF No. 1.) Petitioner challenges his detention as violating his due process rights and seeks immediate release. (Id. at 13–19.) On February 13, 2026, this Court directed Respondent to file a response to Petitioner’s motion. (ECF No. 6.) On February 20, 2026, Respondent filed a response. (ECF No. 7.) On March 5, 2026, Petitioner filed a reply. (ECF No. 12.) For a TRO to issue, courts consider whether Petitioner has established “[1] that he is likely to succeed on the merits, [2] that he is likely to suffer irreparable harm in the absence of preliminary relief, [3] that the balance of equities tips in his favor, and [4] that an injunction is in the public interest.” Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). Petitioner must “make a showing on all four prongs” of the Winter test. Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011). The Court may weigh Petitioner’s showing on each of the Winter factors using a sliding-scale approach. Id. A stronger showing on the balance of the hardships may support issuing a TRO even where there are “serious questions on the merits . . . so long as the [petitioner] also shows that there is a likelihood of irreparable injury and that the injunction is in the public interest.” Id. Simply put, if “serious questions going to the merits were raised [then] the balance of hardships [must] tip[ ] sharply” in Petitioner’s favor in order to succeed in a request for a TRO. Id. at 1134–35. /// The Court considers each of the Winter elements in turn. A. Likelihood of Success on the Merits Petitioner argues that his detention without a bond hearing violates his due process rights. (ECF No. 1 at 13.) In opposition, Respondent claims Petitioner is detained under 8 U.S.C. § 1231(a)(6) (“§ 1231(a)(6)”), which authorizes ICE to detain non-citizens with final orders of removal to effectuate deportation.4 (ECF No. 7 at 2–3.) Respondent argues Petitioner has not even been detained for 60 days and is creating an obstacle to his removal by not assisting with obtaining a travel document. (Id. at 3.) In reply, Petitioner asserts Respondent is incorrect to rely on § 1231(a)(6) because it does not permit immigration officials to re-arrest and re-detain released noncitizens without notice or process at any time after an order of removal has been final for more than 90 days. (ECF No. 12 at 6.) Instead, Petitioner contends that because his final order of removal “became final long ago,” the 90-day removal period has expired and he is subject to supervision under § 1231(a)(3), not detention. (Id.) The Fifth Amendment Due Process Clause prohibits government deprivation of an individual’s life, liberty, or property without due process of law. Hernandez v. Sessions, 872 F.3d 976, 990 (9th Cir. 2017). The Due Process Clause applies to all “persons” within the borders of the United States, regardless of immigration status. Zadvydas v. Davis, 533 U.S. 678, 693 (2001) (“[T]he Due Process Clause applies to all ‘persons’ within the United States, including [noncitizens], whether their presence here is lawful, unlawful, temporary, or permanent.”). These due process rights extend to immigration proceedings, including deportation proceedings. Id. at 693–94; see Demore v. Kim, 538 U.S. 510, 523 (2003). Courts examine procedural due process claims in two steps: the first asks whether there exists a protected liberty interest under the Due Process Clause, and the second examines the procedures necessary to ensure any deprivation of that protected liberty interest accords with the 4 Respondent also makes several arguments about the appropriate form of release available 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.) The Court declines to address these arguments at this juncture. Constitution. See Kentucky Dep’t of Corrections v. Thompson, 490 U.S. 454, 460 (1989); Morrissey v. Brewer, 408 U.S. 471, 481 (1972) (“Once it is determined that due process applies, the question remains what process is due.”). i. Liberty Interest “Freedom from imprisonment — from government custody, detention, or other forms of physical restraint — lies at the heart of the liberty that [the Due Process] Clause protects.” Zadvydas, 533 U.S. at 690. “Even individuals who face significant constraints on their liberty or over whose liberty the government wields significant discretion retain a protected interest in their liberty.” Pinchi v. Noem, 792 F. Supp. 3d 1025, 1032 (N.D. Cal. July 24, 2025). To determine whether an individual’s specific conditional release rises to the level of a protected liberty interest, courts have “compar[ed] the specific conditional release in the case before them with the liberty interest in parole as characterized by Morrissey.” R.D.T.M. v. Wofford, No. 1:25-CV- 01141-KES-SKO, 2025 WL 2617255, at *3 (E.D. Cal. Sept. 9, 2025). Here, Petitioner gained a protected liberty interest in his continued freedom when he was released on supervision in 1999. (ECF No. 1 at 2; ECF No. 12 at 4.) Under Morrissey, this release was an implied promise that Petitioner would not be re-detained during the pendency of his immigration proceedings if he abided by the terms of his release. Petitioner’s liberty interest has been strengthened over time. See, e.g., Doe v. Becerra, 787 F. Supp. 3d 1083, 1093 (E.D. Cal. 2025) (noting the Gover

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

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