Salem v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
SIDI MAHMOUD MOHAMED SALEM,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-580
Honorable Jane M. Beckering
OPINION
Petitioner, a United States Immigration and Customs Enforcement (ICE) detainee currently
detained, initiated this action by filing a counseled petition for a writ of habeas corpus pursuant to
28 U.S.C. § 2241. (Pet., ECF No. 1.) This matter is presently before the Court on Respondents’
motion to dismiss or transfer this matter to the United States District Court for the Southern District
of Texas. (ECF No. 10.) For the following reasons, the Court concludes that it lacks jurisdiction
over the petition. The Court will, therefore, grant Respondents’ motion and will transfer this matter
to the United States District Court for the Southern District of Texas.
Discussion
I. 	Relevant Background
Petitioner is a citizen of Mauritania. (Pet., ECF No. 1, PageID.2.) Petitioner entered the
United States on or about April 3, 2023, without inspection. (Notice to Appear (NTA), ECF No.
11-1, PageID.16.) That same day, a Border Patrol agent encountered and arrested Petitioner (2025
I-213, ECF No. 11-2, PageID.21) and the Department of Homeland Security (DHS) issued
Petitioner a Form I-862, NTA, charging Petitioner with inadmissibility under § 212(a)(6)(A)(i) of
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the Immigration and Nationality Act (INA) because Petitioner is an immigrant “present in the
United States without being admitted or paroled, or who arrived in the United States at any time
or place other than as designated by the Attorney General.” (NTA, ECF No. 11-1, PageID.16.)
On November 12, 2025, ICE agents arrested Petitioner while Petitioner was attending his
regular ICE check-in. (Pet., ECF No. 1, PageID.2; 2025 I-213, ECF No. 11-2, PageID.22.)
Petitioner was “held at El Valle Detention Facility in Raymondville, Texas.” (2025 I-213, ECF
No. 11-2, PageID.22; Notice to EOIR: Alien Address, ECF No. 11-3, PageID.24.) He currently
remains 	at 	the 	El 	Valle 	Detention 	Facility. 	See 	Online 	Detainee 	Locator 	System,
https://locator.ice.gov/odls/#/search (enter “A-Number” 246776499; enter “County of Birth,”
Mauritania, select “Search by A-Number”) (last accessed Mar. 19, 2026); (Detainee Locator
Search Results, ECF No. 11-4, PageID.26) (indicating that Petitioner was detained at the El Valle
Detention Facility as of February 27, 2026).)
On February 19, 2026, Petitioner filed his petition in the United States District Court for
the Southern District of Texas. In Petitioner’s § 2241 petition, Petitioner challenges the lawfulness
of his current detention and asks the Court to, inter alia, assume jurisdiction over this matter and
issue a writ of habeas corpus pursuant to 28 U.S.C. § 2241 ordering Respondents to release
Petitioner from custody. (Pet., ECF No. 1, PageID.29.) He also names the Director of the Detroit
Field Office of ICE as a Respondent and alleges that he is detained at the North Lake Processing
Center in Baldwin, Michigan. (Id., PageID.2, 8.) Citing these allegations, the United States District
Court for the Southern District of Texas transferred this matter to this Court for further
proceedings. (ECF No. 4.)
In an Order entered on February 24, 2026, the Court directed Respondents to show cause,
within three business days, why the writ of habeas corpus and other relief requested by Petitioner
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should not be granted. (Order, ECF No. 9.) On February 27, 2024, Respondents filed a motion to
dismiss or transfer this matter to the United States District Court for the Southern District of Texas.
(ECF No. 10.) In their motion and supporting memorandum, Respondents argue that Petitioner is
and was detained in the Southern District of Texas, not within this District, and that, as a result,
this Court lacks jurisdiction over Petitioner’s § 2241 petition. (ECF No. 11, PageID.10–11.)
Respondents attached to their supporting memorandum Petitioner’s NTA, 2025 I-213, Notice to
EOIR: Alien Address, and a printout of the search results from the ICE Online Detainee Locator
System. (See ECF Nos 11-1, 11-2, 11-3, 11-4.)
In an Order entered on March 13, 2026, the Court directed Petitioner to show cause, within
three business days, why this case should not be transferred to the Southern District of Texas.
Petitioner did not file a response.
II. Legal Standard
The Constitution guarantees that the writ of habeas corpus is “available to every individual
detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) (citing U.S.
Const., Art I, § 9, cl. 2). Section 2241 of Title 28 confers the federal courts with the power to issue
writs of habeas corpus to persons “in custody in violation of the Constitution or laws or treaties of
the United States.” 28 U.S.C. § 2241. This includes challenges by non-citizens in immigration-
related matters. See Zadvydas v. Davis, 533 U.S. 678, 687 (2001); see also A. A. R. P. v. Trump,
145 S. Ct. 1364, 1367 (2025).
“District courts are limited to granting habeas relief ‘within their respective jurisdictions.’”
Rumsfeld v. Padilla, 542 U.S. 426, 442 (2004) (quoting 28 U.S.C. § 2241(a)). “The plain language
of the habeas statute thus confirms the general rule that for core habeas petitions challenging
present physical confinement, jurisdiction lies in only one district: the district of confinement.” Id.
at 443.
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Under 28 U.S.C. § 1406(a) and 28 U.S.C. § 1631, if a district court lacks jurisdiction over
a matter, it may dismiss the case or transfer it to a district where jurisdiction would be proper.
III. Discussion
Petitioner’s allegation that he was detained at the North Lake Processing Center at the time
that he filed his petitioner appears to be a typographical error. The I-213 created at the time of
Petitioner’s arrest and initial detention and search results from the ICE Detainee Locator System
on both February 27, 2026, and March 19, 2026, indicate that Petitioner was and is detained at El
Valle Detention Facility in Raymondville, Texas, located within the Southern District of Texas.
Petitioner has not alleged otherwise in response to this Court’s March 13, 2026, order to show
cause.
Therefore, because this District is not “the district of confinement,” this Court lacks
jurisdiction over Petitioner’s petition for a writ of habeas corpus. See 28 U.S.C. § 2241(a);
Rumsfeld, 542 U.S. at 442. The Court will grant Respondents’ motion and will transfer this matter
to the United States District Court for the Southern District of Texas pursuant to 28 U.S.C. §
1406(a).
Conclusion
For the reasons discussed above, the Court will enter an Order granting Respondents’
motion (ECF No. 10) and will transfer Petitioner’s petition for a writ of habeas corpus pursuant to
28 U.S.C. § 2241 to the United States District Court for the Southern District of Texas pursuant to
28 U.S.C. § 1406(a).
Dated: 	March 19, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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