John v. US Immigration and Customs Enforcement

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
SAMUEL JOHN, 	§
A#035059892, 	§
Petitioner, 	§
§
v. 	§ 	No. 3:25-CV-1844-B-BW
§
U.S. IMMIGRATION AND 	§
CUSTOMS ENFORCEMENT, 	§
Respondent. 	§ 	Referred to U.S. Magistrate Judge1
FINDINGS, CONCLUSIONS, AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE
Before the Court is the amended Petition for a Writ of Habeas Corpus
Pursuant to 28 U.S.C. § 2241, received on October 7, 2025. (Dkt. No. 9.) Based on
the relevant filings and applicable law, the Court should DISMISS the petition
without prejudice as moot.
I. BACKGROUND
Samuel John, then an immigration detainee at the Prairieland Detention
Center in Alvarado, Texas, filed his original habeas corpus petition under 28 U.S.C.
§ 2241 on July 15, 2025, claiming that his prolonged detention by United States
Immigration and Customs Enforcement (“ICE”) violated 8 U.S.C. § 1231(a)(6) and
his due process rights under the Fifth Amendment. (See Dkt. No. 3 at 6.) He sought
immediate release from ICE custody. (See id. at 7.) Respondent filed a response in
opposition to the § 2241 petition on September 4, 2025. (See Dkt. No. 6.) Instead of
1 By Special Order No. 3-251, this habeas case has been automatically referred for
full case management.
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filing a reply, John filed an amended § 2241 petition on October 7, 2025, again
alleging violations of § 1231(a)(6) and his due process rights and seeking immediate
release from ICE custody; the amended petition also included requests for injunctive
relief enjoining his detention and attorneys’ fees and costs. (See id. at 7-9.)
Because it appeared to the Court from available online records that John was
no longer in ICE custody, the Court entered an order on February 2, 2026 requiring
Respondent to file a notice specifically addressing John’s current custodial status and
its effect, if any, on his § 2241 petition. (See Dkt. No. 10.) On February 5, 2026,
Respondent filed a status update seeking dismissal of the petition for lack of
jurisdiction as moot based on John’s removal from the United States. (See Dkt. No.
11.) The supporting document submitted with Respondent’s status update shows
that John was removed from the United States on December 16, 2025. (See id. at 4-
6.)
II. MOOTNESS
“Article III of the Constitution limits . . . federal-court jurisdiction[] to ‘Cases’
and ‘Controversies.’” United States Parole Comm’n v. Geraghty, 445 U.S. 388, 395
(1980). A case becomes moot “when the issues presented are no longer ‘live’ or the
parties lack a legally cognizable interest in the outcome.” Id. at 396 (quoting Powell v.
McCormack, 395 U.S. 486, 496 (1969)).
This case-or-controversy requirement subsists through all stages of
federal judicial proceedings, trial and appellate . . . . The parties must
continue to have a ‘personal stake in the outcome’ of the lawsuit. This
means that, throughout the litigation, the plaintiff “must have suffered,
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or be threatened with, an actual injury traceable to the defendant and
likely to be redressed by a favorable judicial decision.
Spencer v. Kemna, 523 U.S. 1, 7 (1998) (internal citations and quotation marks
omitted).
Here, John contended that his immigration detention by ICE violated
§ 1231(a)(6) and the due process clause of the Fifth Amendment. (See Dkt. No. 9 at
7-8.) In Zadvydas v. Davis, 533 U.S. 678 (2001), the Supreme Court held that
detention of an alien subject to a final order of removal is limited to a period
reasonably necessary to bring about his removal from the United States, which is
presumably six months, and that he must thereafter be released if “there is no
significant likelihood of removal in the reasonably foreseeable future.” Id. at 701.
John challenged only the lawfulness of his prolonged detention and sought
immediate release from ICE custody. (See Dkt. No. 9 at 9.)
Because Respondent’s evidence shows that John is no longer detained and has
been removed from the United States, John’s claims challenging the lawfulness of his
detention are moot. See, e.g., Francis v. Lynch, 622 F. App’x 455, 455-56 (5th Cir.
2015) (holding that the petitioner’s challenge to the duration of his detention pending
removal became moot when he was removed from the United States). The Court
therefore should dismiss John’s § 2241 petition as moot.
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III. RECOMMENDATION
The Court should DISMISS the amended Petition for a Writ of Habeas
Corpus Pursuant to 28 U.S.C. § 2241, received on October 7, 2025 (Dkt. No. 9),
without prejudice as moot.
SO RECOMMENDED on February 6, 2026.
____________________________________
BRIAN McKAY
UNITED STATES MAGISTRATE JUDGE
INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation will be served on all parties in the
manner provided by law. Any party who objects to any part of this report and
recommendation must file specific written objections within 14 days after being
served with a copy. See 28 U.S.C. § 636(b)(1); F ED . R. C IV. P. 72(b). To be specific,
an objection must identify the finding or recommendation to which objection is
made, state the basis for the objection, and indicate the place in the magistrate
judge’s report and recommendation where the disputed determination is found. An
objection that merely incorporates by reference or refers to the briefing before the
magistrate judge is not specific. Failure to file specific written objections will bar the
aggrieved party from appealing the factual findings and legal conclusions of the
magistrate judge that are accepted or adopted by the district court, except upon
grounds of plain error. See Douglass v. United Services Automobile Ass’n, 79 F.3d 1415,
1417 (5th Cir. 1996), modified by statute on other grounds, 28 U.S.C. § 636(b)(1)
(extending the time to file objections to 14 days).
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