Efrain Gomez Sales, an immigration detainee held at California City Correctional Center, successfully challenged his detention through a habeas corpus petition that the court granted based on its recent rulings in similar cases. The case involved constitutional challenges to prolonged immigration detention without adequate due process protections.
Judge Calabretta granted the petition after finding no distinguishing factors from three recent cases where the court ruled in favor of immigration detainees. As the judge noted, 'Respondents submit there are no significant factual or legal issues in this case that materially distinguish it from the cases identified in the Order.' The court had previously ruled on identical legal issues in Garcia Mariagua v. Chestnut, Ortega v. Noem, and Lopez v. Lyons, all decided between November 2025 and December 2025.
The court's order went beyond simple release, establishing strict constitutional requirements for any future detention. Judge Calabretta wrote that respondents are 'permanently enjoined and restrained from re-arresting or re-detaining Petitioner absent compliance with constitutional protections, which include, at a minimum, pre-deprivation notice describing the change of circumstances necessitating Petitioner's arrest and detention, and a timely hearing.'
The case moved swiftly through an expedited process after the court informed parties it intended to rule directly on the petition. Rather than requiring full briefing, Judge Calabretta ordered respondents to show cause whether any factual or legal issues distinguished this case from his prior orders. When respondents conceded there were no material differences and neither party objected to direct ruling, the court proceeded to grant the petition.
The court rejected any potential arguments for continued detention by establishing a high burden for future custody. At any hearing for re-detention, 'the Government shall bear the burden of establishing, by clear and convincing evidence, that Petitioner poses a danger to the community or a risk of flight, and Petitioner shall be allowed to have their counsel present,' Judge Calabretta ruled.
The decision represents part of a broader pattern in the Eastern District of California, where Judge Calabretta has issued at least three similar rulings since November 2025 challenging prolonged immigration detention practices. The court's willingness to streamline these cases suggests growing judicial skepticism of extended detention without adequate procedural protections for immigration detainees.
The order takes effect immediately, with the court directing the clerk to serve California City Detention Facility directly with the release order. Judge Calabretta noted that while the injunction protects against re-detention absent constitutional protections, 'This Order does not address the circumstances in which Respondents may detain Petitioner in the event Petitioner becomes subject to an executable final order of removal.'