Quoc Chi Hoac had a final order of removal to Vietnam from September 2023 and had been released on an Order of Supervision. In June 2025 he was re-detained. Immigration and Customs Enforcement may revoke supervised release only on a showing of changed circumstances making removal significantly likely in the reasonably foreseeable future. The government offered its intention to seek a travel document. The court held that this was not enough: "Respondents’ intent to eventually complete a travel document request for Petitioner does not constitute a changed circumstance", and the fact that the government intends to complete such a request does not make it significantly likely that the person will be removed in the foreseeable future. He was ordered released, and the government was barred from re-detaining him or removing him to a third country without notice and an opportunity for a hearing.
Caution A district court decision, binding on the parties only. An earlier application for a restraining order in the same case had been refused on 30 June 2025, so the sequence matters when the case is cited. The order does not address protection under the Convention against Torture, and nothing in it turns on that.
Redetention Order of supervision Compliance with regulations Prolonged detention (Zadvydas) Third-country removal Notice Due process Changed circumstances
The court's own text
Read from the order of 16 July 2025, obtained free from govinfo and CourtListener. A caution for anyone reading this case from CourtListener by opinion identifier: records 10627266 and 10620830 are both labelled with this case name and contain the text of entirely different cases, an Arkansas criminal appeal and a South Carolina appeal. Only record 10635015 carries the text of this decision.
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