The ruling stems from Abramyan's March 5, 2026 immigration detention and subsequent legal challenge that resulted in a temporary restraining order on March 26 mandating his immediate release. The government had argued that Abramyan's release under the TRO rendered the case moot and sought dismissal, but the court found that argument insufficient to end the litigation.
Judge Court rejected the government's mootness claim, emphasizing the stringent standard required when defendants claim voluntary cessation of allegedly unlawful conduct. 'Respondents have not met their heavy burden to demonstrate that the requested relief is moot since they offer no assurance that their previous wrongs would not recur,' Court wrote, citing Supreme Court precedent requiring defendants to show 'there is no reasonable expectation that the wrong will be repeated.'
The court delivered particularly sharp language in dismissing the government's position, noting that 'the Supreme Court has rejected the idea that temporary relief, like the Court's issuance of the TRO, would moot a habeas petition.' Court emphasized that Abramyan 'continues to face the threat of re-arrest and detention,' making the preliminary injunction necessary.
The case began when immigration officials detained Abramyan on March 5, prompting him to file suit challenging the detention. After the court issued a TRO on March 26 ordering his immediate release, the government was required to show cause why a preliminary injunction should not issue. The government responded on March 30 arguing for dismissal based on mootness, while Abramyan filed his response supporting the injunction on April 6.
The government's central argument that Abramyan's release eliminated any live controversy was firmly rejected by the court, which applied Ninth Circuit precedent requiring a 'stringent' standard for mootness based on voluntary cessation. Court noted that the defendants offered 'no assurance that their previous wrongs would not recur,' failing to meet what she characterized as their 'heavy burden' under established Supreme Court precedent.
The ruling extends a broader trend of federal courts scrutinizing immigration detention practices and requiring due process protections. The court's emphasis on the inadequacy of temporary relief to moot habeas cases aligns with recent Supreme Court precedent in Nielsen v. Preap, which rejected similar mootness arguments in immigration contexts.
The preliminary injunction will remain in effect for the duration of the litigation, preventing immigration officials from re-detaining Abramyan without providing notice and a pre-deprivation hearing. The court also ordered the return of any property confiscated during Abramyan's arrest and processing, and prohibited his transfer outside the Central District of California pending final resolution.