Decisions

D. Md. August 21, 2026 Third country: Guatemala (removal on 10 July 2026; Guatemalan officials refused him and handed him to Mexican officials to be returned to Mexico). He was later removed to Mexico itself, the country of protection, on 1 August 2026.

An immigration judge granted Doe deferral of removal under the Convention Against Torture in July 2024, finding that he was more likely than not to be tortured by the government, or with its acquiescence, if returned to Mexico. The finding rested on his substantial assistance to the Department of Justice and his testimony against defendants affiliated with Mexican drug cartels. Released on an order of supervision in November 2024, he lived in Maryland until he was taken into custody at a routine ICE check-in in January 2026. The court recorded that “Without any notice,” on 10 July 2026 the government removed him to Guatemala; Guatemalan officials refused him and handed him to Mexican officials to be returned to Mexico, but a Mexican consular official, on learning of his protection, had him returned to the United States the same day. On about 15 or 16 July 2026 he was removed a second time, allegedly directly to Mexico, and again returned. On 21 July 2026 the government purportedly served a Notice of Termination of Deferral of Removal, stating that the Department of State had received diplomatic assurances from the Mexican government that he would not be tortured and that the Acting ICE Director and the Secretary of State had found them reliable. The notice “gave no other information or details about the diplomatic assurances,” and bore no Spanish translation although Doe does not speak or read English. The parties agreed that this form of termination “is extremely rare.” On 1 August 2026 he was deported to Mexico, where he has been in hiding. The court held that it had jurisdiction despite 8 U.S.C. § 1252(a)(4) and § 1252(g), because Doe challenged the process used to end his protection, not his removal order, and the route the government chose left no record for a court of appeals to review: “This Court cannot accept the nonsensical result that Doe is unable to obtain judicial review of these executive actions by virtue of the path to termination chosen by the Executive itself.” Adopting the due process analysis of Khouzam v. Attorney General (3d Cir. 2008), which the parties agreed is the only case to have addressed termination on diplomatic assurances, the court found that Doe “was afforded no notice and no hearing whatsoever,” and concluded that “the manner in which Defendants revoked Doe’s CAT Deferral likely violated his procedural due process rights, exceeding the Defendants’ lawful authority.” It took judicial notice of statements by United States officials, and of State Department travel warnings, that “seemingly contradict any diplomatic assurances that the Mexican government can control cartels’ unlawful actions and protect Doe from torture.” Finding the remaining factors met, the court stressed that “There is an immense public interest in ensuring that persons who risk their personal safety to assist the government in prosecuting wrongdoing are not placed in harm’s way by the very entity they assisted,” and, following Noem v. Abrego Garcia, ordered the government to facilitate his return.

CAT deferral Diplomatic assurances Termination without notice Due process Third-country removal Chain refoulement Jurisdiction Jurisdiction 1252(g) Judicial review Access to counsel Remedy

Caution Interim relief only: a temporary restraining order. Much of the account of the removals comes from the complaint and declarations, and the second removal is described as “allegedly” directly to Mexico. The court said an evidentiary hearing would be needed to find the facts about the process provided. It ruled on the process used, not on whether the assurances were reliable or the termination valid. The opinion’s record citations refer to the sealed original case, and the court said an amended version would issue once the pseudonymous refiling was complete. A later memorandum opinion of 14 September 2026 (Document 49) denied the government’s motion for reconsideration, converted the order into a preliminary injunction, recorded that Doe had been returned to the United States, and recorded the government’s new account that the termination notice was served on 1 August 2026, the day of his removal, rather than on 21 July 2026.

9th Cir. June 25, 2026 Investigating. No reporter citation for the order of 25 June 2026 established. The order itself cites the panel opinion as 154 F.4th 989 (9th Cir. 2025). Third country: Mexico. Judge Bea’s statement records that ICE asked Mexico, Nicaragua and Colombia whether they would accept him, and that Mexico agreed because his Mexican humanitarian visa was still in effect.

The Court of Appeals refused to rehear en banc the panel decision of 27 August 2025, which held that 8 U.S.C. 1252(g) did not bar Jorge Felix Ibarra-Perez’s suit for damages under the Federal Tort Claims Act over his removal to Mexico, a country his removal order did not name. The order records: “The matter failed to receive a majority of votes of the nonrecused active judges in favor of en banc consideration.” Judges Hawkins and W. Fletcher recommended denial; Judge R. Nelson voted to grant. Judges Hawkins and W. Fletcher, respecting the denial, wrote: “Ibarra-Perez’s removal order nowhere mentioned Mexico.” They recorded: “Only after proceedings before the IJ were completed did the government designate Mexico as Ibarra-Perez’s country of removal.” Of the contrary reading they wrote: “Our colleagues’ interpretation of § 1252(g) is not only wrong. It is dangerous.” If their colleagues were right, they wrote, § 1252(g) “entirely insulate[s] from judicial review any post-hearing decision by ICE to remove noncitizens to third countries where they would be in danger of persecution, torture, and even death.” Judge Bea, joined by eleven colleagues, also respecting the denial, wrote: “The panel’s divided decision nullified 8 U.S.C. § 1252(g), a basic jurisdiction-stripping provision of the Immigration and Nationality Act (INA).” He wrote that the panel’s interpretation “has been rejected by every other circuit to consider the issue,” and that “many district courts, citing the panel’s misinterpretation of § 1252(g), have exercised jurisdiction over these petitions and enjoined the government from executing these removal orders.” He objected that the panel’s approach “requires DHS, on pain of federal district court disapproval, to obtain an IJ’s sign-off as to the country of removal before executing any removal order.” Judge Bea’s statement sets out the facts of the removal: “On January 15, 2020, ICE agents informed Ibarra-Perez that he would be sent to Mexico.” Then: “Early on the morning of January 16, 2020, about 16 hours after Ibarra-Perez was informed that he would be sent to Mexico, ICE agents executed his removal order and took him to Mexico.” He closed: “I regret that the panel’s confusing, disruptive, and far-reaching decision remains the law of the Ninth Circuit.”

Third-country removal Withholding of removal Country-specific nature of withholding Jurisdiction 1252(g) Judicial review Federal Tort Claims Act Damages

Caution This order only refuses rehearing; it decides nothing new, and the panel opinion of 27 August 2025 stands unamended. Both separate writings are statements respecting the denial of rehearing en banc, not opinions of the court; neither is styled as a dissent. Judge Bea’s statement is joined by eleven judges, twelve in all. The order does not give the vote count. The facts of the removal summarized above come from Judge Bea’s statement. The underlying case is a claim for damages, returned to the district court in Arizona; it does not decide whether the removal was lawful. Footnote 1 of Judge Bea’s statement lists district court orders that relied on the panel decision, including Soliman v. Warden (E.D. Cal.), which is in the register.

D. Md. May 27, 2026 Third country: Mexico (intent to remove announced on 31 July 2025; removed to Villahermosa, Tabasco, on 26 September 2025).

Mr. Orellana Quintanilla received a notice reinstating a prior removal order on 2 October 2015 and was granted withholding of removal to El Salvador on 3 January 2019. Released on an order of supervision on 10 January 2019, he lived and worked in Maryland for more than six years. On 31 July 2025 his supervision was revoked, ICE took him back into custody, and the government told him the same day that it intended to remove him to Mexico. His lawyers asked for a reasonable fear interview by e-mail on 16, 24 and 25 September 2025. The last request attached his signed statement about the MS-13 gang that killed his uncle: “I am afraid they will harm or even kill me.” On the evening of 25 September he asked the court for a temporary restraining order; on the morning of 26 September 2025 ICE officers removed him to Villahermosa, Tabasco, Mexico, without an interview. It was undisputed that an immigration judge had found it “more likely than not that the Plaintiff would be persecuted or tortured if he is returned to his home country of El Salvador.” The court held that he was likely to succeed on his claim that the government violated the reasonable fear regulations and DHS policy: “The Plaintiff’s removal under these circumstances is plainly in violation of DHS’s RFI regulations.” It did “not agree with the Defendants that Congress intended for a third country removal to fall outside the scope of these regulations,” and read them to apply “whenever a person asserts a fear of being sent to the country to which the Defendants seek removal, regardless of whether that country is the person’s country of origin.” The court denied the motion to dismiss, rejecting the government’s arguments under 8 U.S.C. § 1252(g), on venue, and based on the pending D.V.D. class action, noting that “no final judgment has been entered by the district court in that class action litigation.” It found irreparable harm because he is in hiding in Mexico and fears being sent on to El Salvador. Relying on Noem v. Abrego Garcia, it held that it may order the government to facilitate his return “as a remedy for the unlawful removal at issue in this case.”

Third-country removal Reasonable fear Withholding of removal Revocation of supervision Compliance with regulations Jurisdiction 1252(g) D.V.D. class action Venue Remedy

Caution Interim relief only: a preliminary injunction granted in part. The opinion is dated and filed 27 May 2026 but explains an order the court issued on 19 May 2026, after a hearing that day, and incorporates reasons “stated during the May 19, 2026, hearing,” which are not in the file. The opinion does not say which part of the motion was refused; a request for parole documents was withdrawn at the hearing. That he is in hiding in Mexico and that ICE kept his passport and other identity documents are recorded as his allegations. The docket shows further proceedings in August 2026, including a hearing set for 11 August 2026, which have not been reviewed; whether he has been returned is not stated in this opinion.

N.D. Ind. May 22, 2026 Third country: None identified in the order. The government identified Iran as the only country under consideration.

The petitioner, an Iranian citizen who entered the United States in 1999, was ordered removed on 13 November 2002 after criminal convictions in Illinois. ICE released him on an order of supervision on 22 October 2012, and he remained on release for nearly thirteen years until ICE detained him on 17 September 2025. He was held at the Miami Correctional Facility, a facility of the Indiana Department of Correction, and filed the petition without a lawyer. The court held, by reference to its earlier decision in Liang v. English, that “jurisdiction is secure insofar as this opinion goes,” despite the government’s reliance on 8 U.S.C. § 1252(g) and § 1252(b)(9). The government identified Iran as the only country under consideration. An ICE official attested on 13 April 2026 that “the airspace over Iran is closed which has paused removals to Iran” and that “[r]emovals will resume once the airspace reopens.” The court found that the petitioner had shown good reason to believe removal was not foreseeable, noting the recent military conflict “between the United States and Iran and the present uncertainty of a resolution, which reasonably impedes any removal to Iran for the foreseeable future.” The court held that the government had not rebutted that showing. It found that “the precise relationship between the efforts to remove Mr. Khodabakhsh and the closure of Iran’s airspace is unclear,” that “it is less clear how closed airspace would hinder efforts to obtain travel documents,” and that the government did not explain why travel documents had not been obtained “after eight months of detention, five of which predate the current conflict with Iran,” or suggest that a formal request had been submitted. The court said it “has no insight into if or when an agreement allowing removals to continue might be reached. More important, the government has presented no such insight, so has not met its burden today.” It ordered his release on the same conditions as his last release, adding that efforts to remove him “may continue while he returns to supervision.”

Prolonged detention (Zadvydas) Redetention Order of supervision Travel documents Jurisdiction 1252(g) Self-represented petitioner

Caution A district court decision, binding only on the parties. The order concerns detention only: removal to Iran remains the government’s stated aim, and the court said efforts to remove him may continue. No third country and no protection from removal appear in the order. The court’s assessment of the conflict with Iran and the closure of Iranian airspace is as of 22 May 2026.

D. Nev. April 24, 2026 Third country: None identified in the order.

Mr. Hassan was admitted to the United States in 2006 as a Sudanese refugee “fleeing genocide.” He was ordered removed on 8 February 2021 because of criminal convictions, but the immigration judge deferred his removal to Sudan under the Convention Against Torture “because it is likely that he will be tortured if returned to that country.” He was held for about 90 days and released because the government could not carry out his removal. On 15 January 2026 he was arrested in Weber, Utah, for riding a train without a ticket; four days later ICE took him into custody and moved him to the Nevada Southern Detention Center. The court counted his 2021 detention together with his 2026 detention, holding that “the government cannot simply restart the six-month clock whenever it chooses to re-detain him.” It found the government’s response “woefully insufficient to show that there is a significant likelihood of Hassan’s removal at all, let alone in the reasonably foreseeable future,” and granted the petition on that ground. It also held that ICE had given him neither notice of the reasons for revoking his release nor an informal interview: “It’s undisputed that those regulations were not followed here.” On third-country removal, the court described an ICE policy under which no notice or opportunity to be heard is given where “the United States has received diplomatic assurances from the country of removal that [noncitizens] removed from the United States will not be persecuted or tortured” and the Department of State deems them credible, and which otherwise allows removal on as little as six hours’ notice without asking whether the person fears removal. It held that where assurances are relied on, “Notice, let alone an opportunity to be heard, is not available to a noncitizen in that situation,” and that the notice route “does not comport with the fundamental requirements of due process.” Because removal to Sudan is deferred, the court found that any removal “will likely be effectuated under its unconstitutional third-country-removal policy.” It barred removal to any country not listed on his removal order unless the government first meets the requirements the order sets out: notice, asking whether he fears persecution or harm in the designated country and recording the answer in writing, telling him that he may seek protection by a motion to reopen, and adequate time to prepare and file it.

Prolonged detention (Zadvydas) Redetention Revocation of supervision Informal interview Compliance with regulations Third-country removal Notice Diplomatic assurances Due process CAT deferral Jurisdiction 1252(g) Changed circumstances

Caution The ruling on the third-country policy concerns the policy as described in the record (ECF No. 8-5); no particular third country had been designated for him. The court did not reach his separate constitutional challenge to prolonged detention or his claim under the Administrative Procedure Act. The government filed its response late, and the court accepted it. After the order, the docket shows a motion to enforce filed on 27 April 2026 and a minute order on it on 1 May 2026, which have not been reviewed.

D. Nev. April 7, 2026 Third country: None identified in the order.

Mr. Alvarez Guerra was born and raised in Cuba and has no citizenship or lawful immigration status in any other country. He entered the United States on 21 June 2023 using the CBP One app and applied for residency in July 2024. He was arrested on 10 March 2025 and has been detained since. On 21 May 2025 an immigration judge denied asylum but granted withholding of removal from Cuba; the Board of Immigration Appeals denied his asylum appeal on 22 January 2026, when the removal order became final. The government argued that 8 U.S.C. § 1252(g), § 1252(a)(5) and § 1252(b)(9) barred review. Following Ibarra-Perez v. United States (9th Cir. 2025), the court held that § 1252(g) “does not divest this Court of jurisdiction over Petitioner’s request to prohibit his removal to a third country without sufficient notice and an opportunity to raise fear-based claims,” and called the argument that his only avenue was a petition for review in the court of appeals “patently false.” The government did not respond to the third-country claim. The court held that the petitioner “has a due process right to receive meaningful notice and opportunity to present a fear-based claim to an immigration judge before DHS deports him to a third country,” and granted that ground without reaching the claim under the Administrative Procedure Act. The parties agreed that the 90-day removal period would end on 22 April 2026, and the court held: “Because detention is mandatory during the removal period, Petitioner’s detention is currently lawful.” His claim that he had not received a custody review was premature for the same reason. The court denied release, declined to stay the case, and closed it so that he may file a new habeas case later.

Third-country removal Notice Due process Withholding of removal Reopened removal proceedings Jurisdiction 1252(g) Jurisdiction 1252(a)(5) Jurisdiction 1252(b)(9) Ripeness

Caution The order was signed on 7 April 2026 and entered on the docket, with the judgment, on 8 April 2026. The detention claims were denied without prejudice only because the removal period had not yet ended. No particular third country had been designated, and the order does not address diplomatic assurances.

M.D. Fla. March 20, 2026 2026 WL 787639 Third country: Mexico

Because ICE gave written notice and an informal interview, the petitioner received what the Fifth Amendment requires, and his Zadvydas claim was premature at four months; the petition was denied.

Redetention Notice Informal interview Prolonged detention (Zadvydas) Jurisdiction 1252(g) Jurisdiction 1252(b)(9)

Caution Denied without prejudice to refiling after six months. This is a different petitioner from Chavez Barrios v. Ripa and the brief warns that the two Barrios cases must be kept separate in every list.

D.N.M. December 4, 2025 Third country: In 2025 the government asked El Salvador, Honduras, Guatemala, the Dominican Republic and Peru to accept him; Honduras, the Dominican Republic and Peru declined. It also contacted ICE’s Middle East/East Africa Removal Division. Several countries, not named, declined in 2016 and 2017. The court recorded that at least five countries declined to accept him between 2016 and 2025.

The petitioner, a citizen of Mexico, was ordered removed to Mexico on 26 May 2016 and at the same time granted deferral of removal under the Convention Against Torture, “based on testimony and evidence that his life would be in danger if he returned to Mexico.” The government held him while it sought a third country and, after several countries declined, released him on an order of supervision on 9 March 2017. He missed an ICE appointment on 1 March 2023. On 14 February 2025 he was arrested at a Border Patrol checkpoint in New Mexico and detained at the Otero County Processing Center while the government again sought a third country. In June 2025 his former counsel asked to drop the deferral so he could be removed to Mexico; an immigration judge granted reopening and termination on 17 September 2025 without addressing his later motion to withdraw that request, and his appeal is pending. The court recorded that “the parties agreed that Petitioner’s CAT deferral remains legally operative during the pendency of the BIA appeal.” The court rejected the government’s argument that 8 U.S.C. 1252(g) and (b)(9) barred review: “The government’s detention of Petitioner lacks the direct link to his removal proceedings or to the execution of his removal order to fall under the ambit of § 1252(g) or § 1252(b)(9).” It counted the four months he spent in detention in 2016 and 2017 toward the six-month period under Zadvydas v. Davis, stating that it “is disinclined to allow such gamesmanship by the government.” On the prospect of removal, the court found: “The government has also not been able to identify a third country to accept Petitioner.” It added that “between 2016 and 2025, at least five countries have declined to accept him,” and that even if a country agreed, “Petitioner may be entitled to notice and an opportunity to seek protection from removal, further prolonging his detention should he be allowed to remain in custody.” It held: “Because Petitioner has been detained more than six months and his removal is not reasonably foreseeable, his ongoing detention violates the INA.” It excused the failure to seek administrative review under 8 C.F.R. 241.13. The court did not decide whether the revocation of his supervision was lawful, but noted: “The government has provided no information about who made the decision to revoke Petitioner’s Order of Supervision, and whether it complied with § 241.4(l)(2) such that no notice or hearing was required.”

CAT deferral Third-country removal Prolonged detention (Zadvydas) Redetention Revocation of supervision Order of supervision Jurisdiction 1252(g) Notice Informal interview

Caution Release rests on prolonged detention under Zadvydas alone. The court expressly did not decide whether the arrest and the revocation of supervision without notice or an interview were lawful, and it did not grant the requested order requiring notice and an opportunity to seek protection before any removal to a third country. The deferral was the subject of a pending appeal to the Board of Immigration Appeals; the government argued that he would already have been removed to Mexico if not for that appeal. The court’s docket text records that the main document was replaced on 5 December 2025 at chambers’ request; the copy read is the court’s copy of Doc. 30, filed 4 December 2025, as published on govinfo.gov, and it matches the web printout on the site in substance.

N.D. Cal. October 10, 2025 2025 U.S. Dist. LEXIS 201666; 2025 WL 2899220 Third country: Jordan

Serious questions exist that the petitioner may not be detained without notice and a hearing before an immigration judge, or removed to a third country without notice and an opportunity to apply for fear-based relief.

Redetention Notice Third-country designation CAT deferral Prolonged detention (Zadvydas) Jurisdiction 1252(g) Jurisdiction 1252(a)(5) Jurisdiction 1252(b)(9)

Caution Preliminary injunction on a 'serious questions' showing, not a final merits ruling; issued by a magistrate judge, and the file does not state whether the parties consented; the supplied file is named for the July 26, 2025 temporary restraining order but contains the October 10, 2025 order.

S.D. Tex. September 26, 2025 2025 WL 2774610

ICE re-detained the petitioner without a shown lawful revocation, notice of reasons, or the required informal interview, and his removal is not reasonably foreseeable; release was ordered with notice required once a third country is identified.

Redetention Informal interview Notice Prolonged detention (Zadvydas) Withholding of removal Third-country designation Jurisdiction 1252(g)

Caution The third-country notice claim was held premature even as summary judgment on it was denied, and no fixed notice period was set; final judgment was to be entered separately and is not in the file; the government produced no copy of any order revoking supervision; the court noted a split on whether the six-month period resets on re-detention.

E.D. Cal. September 18, 2025 2025 WL 2675760 Third country: Kenya, Eritrea, Somalia, or Benin (mentioned to the petitioner; none secured)

The court enjoined third-country removal without written notice, a minimum of ten days to raise a Convention Against Torture claim, and reopening or fifteen days to seek reopening, but declined to order release under Zadvydas.

Notice Third-country designation CAT deferral Withholding of removal Prolonged detention (Zadvydas) Bond hearing Jurisdiction 1252(g) Diplomatic assurances

Caution Preliminary injunction converted from a temporary restraining order with merits briefing to follow, although the decretal paragraph says 'permanently enjoined'; the bond hearing within 30 days, which the government requested, appears in the analysis but not in the numbered decretal paragraphs; the judge is not named anywhere in the printout; the assurances material comes from the court's quotation of ICE's July 9, 2025 policy, not from any assurance in this case.

S.D. Fla. September 9, 2025 824 F. Supp. 3d 1243

The revocation itself was authorized under section 241.4(l)(2)(iii), but the check-in desk conversation was not the required informal interview after return to custody, so seventy-five days of detention without a meaningful opportunity to be heard violated due process.

Redetention Informal interview Notice CAT deferral Jurisdiction 1252(g)

Caution Section 241.4 applied rather than section 241.13 because the petitioner never obtained a section 241.13 determination; the court flagged its disagreement with Chavez Barrios v. Ripa, a decision of the same district, on whether section 241.4(l)(1) process attaches to an (l)(2) revocation; the court retained jurisdiction to enforce.

D. Md. September 8, 2025 2025 WL 2592543 Third country: Australia and Romania

Detention is not authorized by section 1231(a)(6) because, with withholding granted as to Iran and no response from Australia or Romania, there is no significant likelihood of removal in the reasonably foreseeable future.

Redetention Prolonged detention (Zadvydas) Withholding of removal Third-country designation Notice Jurisdiction 1252(g)

Caution The six-month Zadvydas presumption was assumed without deciding to apply; the third-country notice claim was stayed because the petitioner is a D.V.D. class member, so the court did not rule on what process is due before a third-country removal; the separate order carrying the decretal terms of release is not in the file.

S.D.N.Y. August 26, 2025 798 F. Supp. 3d 400

The government gave no notice of revocation and no interview before re-detaining a man released in 2018, violating its own regulations and due process; release was ordered, and transfer after filing did not defeat jurisdiction.

Redetention Notice Informal interview Jurisdiction 1252(g) Transfer out of district

Caution Granted in part. The court's description of Westley v. Harper as reaching the merits of the section 241.4(l) claim is in tension with the project's earlier note that Westley was dismissed for want of jurisdiction, and the brief directs that neither characterisation be published until the Westley opinion itself is read.

E.D. Cal. August 20, 2025 2025 WL 2791778

The re-detention was unlawful because ICE gave no informal interview and showed no changed circumstances making removal to China reasonably foreseeable; release was ordered and re-detention barred without notice and a pre-detention hearing before an immigration judge.

Redetention Informal interview Notice Prolonged detention (Zadvydas) Third-country designation Jurisdiction 1252(g)

Caution Temporary restraining order granted in part on a preliminary record, with a preliminary-injunction schedule to follow; the request to enjoin third-country removal was denied without prejudice as not ripe; the order introduces 'five claims' and then lists six, and several regulatory citations are printed irregularly.

S.D. Fla. August 8, 2025 2025 WL 2280485; 2025 U.S. Dist. LEXIS 153228 Third country: Guatemala

The emergency motion was denied: section 241.4(l)(2) required no notice or interview and both were in fact given, the Zadvydas claim was premature, and the regulatory stay barred removal to Mexico only.

Redetention Informal interview Notice Prolonged detention (Zadvydas) CAT deferral Third-country designation Jurisdiction 1252(g) Transfer out of district Bond hearing

Caution The brief records that this decision resolves the project's ledger claim 10 against the version previously carried: the motion was denied, and no appellate stay is supported, only the district court's interim order of June 12, 2025 staying transfer and removal. The decision splits from Grigorian, Zhu, Ceesay and Torres on whether section 241.4(l)(1) process attaches to an (l)(2) revocation, and from Gonzalez v. Noem and Zhu on jurisdiction to restrain a transfer.

N.D. Cal. August 6, 2025 2025 WL 2243616

Serious questions exist that due process bars detention or removal to any third country without notice and an opportunity to present a fear-based claim; sections 1252(g), (a)(5), (b)(9) and FARRA do not bar review.

Redetention Notice Third-country designation CAT deferral Prolonged detention (Zadvydas) Jurisdiction 1252(g) Jurisdiction 1252(a)(5) Jurisdiction 1252(b)(9)

Caution Preliminary injunction on the 'serious questions' standard, converted from a temporary restraining order by consent; every merits finding is framed as a serious question and none is final; no third country is identified anywhere in the file, and the court did not identify the governing detention statute by number.