Ever Edgardo Mendez, a long-term U.S. resident held at California City Correctional Center, challenged his ongoing immigration detention through a habeas corpus petition filed under 28 U.S.C. § 2241. The case centered on whether immigration authorities violated federal law by detaining Mendez without providing him a statutorily required bond hearing under 8 U.S.C. § 1226(a), which governs discretionary detention during removal proceedings.
Judge Coggins granted both Mendez's petition for habeas corpus and his motion for a temporary restraining order, following a line of recent decisions from her court addressing similar detention issues. The judge ruled that "a noncitizen who has lived in the United States for an extended period of time without having been admitted is subject to discretionary detention during removal proceedings pursuant to 8 U.S.C. § 1226(a) and is entitled to a pre-deprivation bond hearing under that section."
The court found that "the proper remedy for Respondent's failure to provide Petitioner with a statutorily compliant bond hearing is Petitioner's immediate release," citing her recent decision in Zuniga Cruz v. Noem. The ruling prohibited immigration authorities from imposing additional restrictions like electronic monitoring unless determined necessary at a future custody hearing.
The case followed a streamlined procedural path after Judge Coggins asked both parties whether they opposed simultaneous resolution of the temporary restraining order and habeas petition. Government attorneys acknowledged in their April 8 opposition filing that "there are no significant factual or legal issues in this case that materially distinguish it from" the court's prior decisions in Alvarez Maciel v. Noem and Barajas Ortiz v. Chestnut, both decided earlier this year.
Respondents conceded the legal framework established in the judge's previous rulings, with government counsel stating that "if the Court is inclined to grant a preliminary injunction, judicial economy counsels that the Court should go further and enter a final judgment granting habeas corpus on the merits." Judge Coggins noted that 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 would grant the relief sought.
The ruling represents part of a growing trend in the Eastern District of California, where Judge Coggins has issued similar orders in multiple cases this year. In Alvarez Maciel, she granted injunctive relief for a noncitizen detained after living in the United States for over twenty years, while in Barajas Ortiz, she ruled similarly for someone who had lived in the country for over thirty years. The Zuniga Cruz decision involved a petitioner who had lived in the United States for eight years before detention.
Under the court's order, if the government seeks to re-detain Mendez, they must provide him with a bond hearing pursuant to federal regulations where he would bear the burden of showing he is not a flight risk or danger to community safety. The ruling does not address circumstances where Mendez might be detained if he becomes subject to a final order of removal and receives proper notice.