The case involves S.H., an immigrant who was previously released on bond or parole but was re-detained in November 2025 by immigration authorities. The petitioner, whose identity is redacted in court filings, challenged his ongoing detention through a habeas corpus petition, arguing that the government violated his constitutional rights by locking him up again without providing a hearing before a neutral decision-maker.
Judge Coggins found that the Due Process Clause requires the government to provide a pre-deprivation bond hearing before re-detaining immigrants who were previously released. As she explained in her order, 'this court has found that the Due Process Clause requires that, in order for the government to re-detain a noncitizen who has been previously released on bond or conditional parole under 8 U.S.C. § 1226(a), or humanitarian parole under 8 U.S.C. § 1182(d)(5), the government must provide a pre-deprivation bond hearing before a neutral arbiter at which the noncitizen's eligibility for bond must be considered.'
The ruling represents the latest in a string of similar decisions from Judge Coggins' courtroom. The government acknowledged in its opposition that 'there are no significant factual or legal issues in this case that materially distinguish it from' earlier cases where the judge had reached identical conclusions, including Selis Tinoco v. Noem, Labrador-Prato v. Noem, and D.L.C. v. Wofford.
The case reached resolution unusually quickly after Judge Coggins asked both sides whether they opposed simultaneous resolution of both the preliminary injunction motion and the underlying habeas petition. Government lawyers indicated they 'do not oppose the Court entering a final judgment granting habeas corpus on the merits' if injunctive relief was granted, effectively conceding the case after their string of losses on the same legal theory.
The government had opposed the motion 'on the same grounds as those addressed by the court in the aforementioned cases,' but Judge Coggins found their arguments unpersuasive for the same reasons she had rejected them before. Because 'Respondents have not made any new legal arguments and have not identified any factual or legal issues in this case that would distinguish it from the court's aforementioned prior decisions,' she granted both the injunction and the habeas petition.
The order establishes specific protections for S.H. going forward: he must be released immediately under the same conditions that applied before his November detention, and if the government wants to detain him again, it must provide at least seven days' notice and hold a pre-deprivation bond hearing. Judge Coggins specified that 'Respondents shall not impose any additional restriction on him, such as electronic monitoring, unless that is determined to be necessary at a future pre-deprivation/custody hearing.'
The ruling adds to growing pressure on immigration authorities in the Eastern District of California, where Judge Coggins has consistently found that re-detention without hearings violates constitutional due process rights. The decision could influence how Immigration and Customs Enforcement handles cases involving previously released immigrants throughout the district, potentially requiring the agency to provide bond hearings before re-detention in similar circumstances.