Writing for the court, Circuit Judge Rao held that the district court's expanding inquiry into the transfers was an abuse of discretion. The original order, the panel concluded, lacked the clarity required to support criminal contempt based on the transfer of custody to Salvadoran authorities.
The underlying dispute began after the President invoked the Alien Enemies Act against Tren de Aragua, a Venezuelan criminal gang designated as a foreign terrorist organization. On March 15, 2025, the government placed alleged gang members on planes to El Salvador. The district court issued a temporary restraining order, but the Supreme Court later vacated it, ruling that the plaintiffs' habeas claims belonged in a different venue.
Despite the vacatur, the district court moved forward with criminal contempt proceedings, concluding that the government had willfully disobeyed the order by transferring custody. The government identified then-Secretary of Homeland Security Kristi Noem as the official responsible for the transfer decision.
The district court then expanded its inquiry, ordering further hearings to obtain information from government counsel about the events of March 15. The D.C. Circuit concluded that the inquiry improperly probed "high-level Executive Branch deliberations regarding national security and diplomacy."
Judge Rao wrote that additional judicial investigation was unnecessary because the government had already identified the responsible official. The opinion said the district court's actions impaired the Executive Branch's constitutional duties.
The writ was issued to prevent the district court from assuming "an antagonistic jurisdiction that encroaches on the autonomy of the Executive Branch." The mandamus petition was docketed as No. 25-5452, arising from underlying litigation in No. 1:25-cv-00766. Concurring and dissenting opinions were also filed.