Meriani v. Noem et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
Meriani Meriani
(A#078-569-377),
Petitioner,
v.
Kristi Noem, et al.,
Respondents.
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Civil Action H-26-0033
MEMORANDUM AND RECOMMENDATION
Meriani Meriani, through counsel, filed a petition for writ of
habeas corpus on January 4, 2026. ECF No. 1. Meriani challenges
the constitutionality of her continued detention by United States
Department of Homeland Security, Immigration and Customs
Enforcement.
In an “Advisory” filed on March 8, 2026, counsel for the
Government 	advised 	the 	court 	that 	the 	Petitioner 	had 	been
removed from the United States and that this action is now moot.
ECF No. 7. Based on the Advisory, the court ordered Petitioner’s
counsel to notify the court by March 20, 2026, whether this action
is moot. ECF No. 8. Petitioner did not file anything in response to
the 	court’s 	order. 	Thus, 	Petitioner 	has 	not 	rebutted 	the
Government’s representation that she has been removed. A search
in 	the 	U.S. 	Immigration 	and 	Customs 	Enforcement 	Online
Detainee Locator System, <https://locator.ice.gov/odls/#/search>,
on March 23, 2026, returned no results for Petitioner’s A-Number.
The court concludes that Petitioner has been removed from the
United States and is therefore no longer in the government’s
physical custody.
United States District Court
Southern District of Texas
ENTERED
March 24, 2026
Nathan Ochsner, Clerk
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Although 	Petitioner 	was 	in 	“custody” 	for 	purposes 	of
28 U.S.C. § 2241 when she filed her petition, her removal renders
her petition moot. See Alvarez Colina v. Gillis, 2022 WL 1001437
(5th Cir. 2022) (unpublished). The court therefore recommends
that this case be DISMISSED without prejudice as MOOT.
The 	parties 	have 	fourteen 	days 	from 	service 	of 	this
memorandum and recommendation to file written objections. See
Rule 	8(b) 	of 	the 	Rules 	Governing 	Section 	2254 	Cases;
28 U.S.C. § 636(b)(1)(c); Fed. R. Civ. P. 72. Failure to timely file
objections will preclude appellate review of factual findings or legal
conclusions, 	except 	for 	plain 	error. 	See 	Thomas 	v. 	Arn, 	474
U.S. 140, 147-49 (1985); Rodriguez v. Bowen, 857 F.2d 275, 276-77
(5th Cir. 1988).
Signed at Houston, Texas, on March 24, 2026.
______________________________________
Peter Bray
United States Magistrate Judge
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