Decisions

S.D. Fla. August 18, 2025

The case concerned the operations of the Florida detention facility commonly called Alligator Alcatraz. The court opened its order by locating it: “This case involves the operations of Alligator Alcatraz, a detention facility designed by the State of Florida and located in Collier County, in the Middle District of Florida.” Detained plaintiffs, together with attorneys and organisations, alleged that state and federal officials had blocked confidential communication between people held at the facility and their lawyers, in breach of the First Amendment. A group of the detained plaintiffs separately alleged that the Executive Office for Immigration Review had breached the Fifth Amendment by failing to identify an immigration court with jurisdiction over their cases. The court dismissed the Fifth Amendment claim: “The Fifth Amendment claim is moot and must be dismissed.” It had been “premised entirely on the contention that ‘Defendants have failed to identify which immigration court has jurisdiction over Alligator Alcatraz.’” Two days before the order the government had given notice that the Executive Office for Immigration Review had designated Krome as the administrative control court for the facility. The court rejected both the capable-of-repetition and the voluntary-cessation exceptions. The court did not decide the First Amendment claims. It held that venue was improper: “Plaintiffs have failed to make a prima facie showing that the alleged events substantially occurred here, in the Southern District of Florida.” The claims were transferred to the Middle District of Florida, where the facility sits. The court noted that the airport on which the facility was built “mostly sits in Collier County, though a small portion of the runway juts into Miami-Dade County.”

Access to counsel First Amendment Fifth Amendment Immigration court jurisdiction Venue Mootness Conditions of detention

Caution This decision settles where the case is heard and whether one claim survives. It makes no finding about conditions at the facility and no finding about the treatment of anyone held there. A reporter citation for this decision, 796 F. Supp. 3d 1198, is in circulation. The Coalition has not been able to verify it against any primary source and does not reproduce it. The docket number and the date above are verified from the court record. The transferred case continued in the Middle District of Florida as H.C.R. v. Noem, No. 2:25-cv-00747, recorded separately in this register.