Iglesias Parada v. Unknown Party et al

ORDER DENYING MOTION FOR IMMEDIATE RELEASE - 1
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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT TACOMA
JOSE RODOLFO IGLESIAS PARADA,
Petitioner,
v.
WARDEN, NORTHWEST ICE
PROCESSING CENTER; FIELD OFFICE
DIRECTOR, ICE SEATTLE; SECRETARY,
DEPARTMENT OF HOMELAND
SECURITY; ATTORNEY GENERAL OF
THE UNITED STATES,
Respondents.
Case No. 2:26-cv-00947-TMC
ORDER DENYING MOTION FOR
IMMEDIATE RELEASE
Before the Court is self-represented petitioner Jose Rodolfo Iglesias Parada’s
(“Mr. Iglesias Parada”) “motion for immediate release or, in the alternative, for a bond hearing.”
Dkt. 2. A document filed by a self-represented litigant is to be liberally construed. Erickson v.
Pardus, 551 U.S. 89, 94 (2007). Given that Mr. Iglesias Parada is representing himself, the Court
will treat his motion as one for a temporary restraining order (“TRO”). For the reason explained
below, Mr. Iglesias Parada’s motion for a TRO is DENIED. His habeas petition will be handled
promptly based on the scheduling order entered at Dkt. 4.
Mr. Iglesias Parada was arrested by Immigration and Customs Enforcement (“ICE”) on
March 6, 2026, and has been detained within the Northwest ICE Processing Center (“NWIPC”)
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ever since. Dkt. 1 at 1–2. On March 20, 2026, Mr. Iglesias Parada began this case with two
filings. The first is a petition for writ of habeas corpus. Dkt. 1. With this petition, Mr. Iglesias
Parada seeks release from immigration detention, or alternatively, an order requiring a bond
hearing before an immigration judge. Id. at 2. The second filing is the instant motion for a TRO
seeking the same relief. Dkt. 2.
A party seeking a TRO “must establish that he is likely to succeed on the merits, that he
is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of
equities tips in his favor, and that an injunction is in the public interest.” Winter v. Nat. Res. Def.
Council, Inc., 555 U.S. 7, 20 (2008); United States v. City of Seattle, 474 F. Supp. 3d 1181, 1185
(W.D. Wash. 2020) (“The standard for issuing a TRO is the same as the standard for issuing a
preliminary injunction.”). When a party seeks a TRO against the government, the third and
fourth factors merge. Drakes Bay Oyster Co. v. Jewell, 747 F.3d 1073, 1092 (9th Cir. 2014). In
the Ninth Circuit, a party may also obtain a TRO by demonstrating “‘serious questions going to
the merits’ and a balance of hardships that tips sharply” in the party’s favor, so long as the party
also shows “that there is a likelihood of irreparable injury and that the injunction is in the public
interest.” Fraihat v. U.S. Immigr. & Customs Enf’t, 16 F.4th 613, 635 (9th Cir. 2021) (quoting
All. for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1135 (9th Cir. 2011)); City of Seattle, 474 F.
Supp. 3d at 1185–87 (applying the “serious questions” standard to a request for a TRO).
Mr. Iglesias Parada fails to show a likelihood of irreparable harm without preliminary
relief. His motion seeks to obtain the relief sought in his habeas petition on an expedited basis.
As explained in this Court’s General Order 10-25 on immigration habeas petitions, this type of
filing is discouraged, and “[m]otions for temporary restraining orders should be reserved for
matters where the petitioner alleges imminent, irreparable harm, such as imminent removal from
the United States.” General Order 10-25 (Dec. 18, 2025). This District is handling an
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unprecedented volume of immigration habeas cases, all of which, by their very nature, concern
petitioners who allege they are unlawfully in custody. The Court does its best to rule on each
petition promptly, but it will generally not consider emergency motions that seek the same
underlying relief without a showing of imminent, irreparable harm separate from ongoing
detention. Furthermore, the Court’s scheduling order provides a procedure for either party to
request expedited briefing on the habeas petition. See Dkt. 4.
Mr. Iglesias Parada’s motion does not show a likelihood of imminent transfer from this
district, removal from the United States, or other irreparable harm. Consistent with General
Order 10-25 and this Court’s scheduling order, Respondents must provide Mr. Iglesias Parada
“least 48 hours’ notice (or 72 hours’ notice if the period extends into a weekend, holiday, or date
the Court is closed) prior to any action to move or transfer [him] from the Western District of
Washington or to remove [him] from the United States.” Dkt. 4 ¶ 3. This notice allows
Mr. Iglesias Parada to seek emergency relief if needed. No further restrictions are warranted
now.
Because Mr. Iglesias Parada has not met the standard for a TRO, the Court DENIES his
motion. Dkt. 2.
The Clerk is directed to send uncertified copies of this Order to all counsel of record and
to any party appearing pro se at said party’s last known address.
Dated this 20th day of March, 2026.
Tiffany M. Cartwright
United States District Judge
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