Mohamed v. Raycraft

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______

ABDULHAKIM MOHAMED,

Petitioner,

v.

KEVIN RAYCRAFT,

Respondent.
____________________________/

Case No. 1:26-cv-2220

Honorable Paul L. Maloney

OPINION
Petitioner, a former United States Immigration and Customs Enforcement (ICE) detainee,
initiated this action by filing a pro se petition for a writ of habeas corpus pursuant to 28 U.S.C.
§ 2241, (Pet., ECF No. 1), and a brief in support of the petition. (Br. Supp., ECF No. 2.) For the
following reasons, the Court will dismiss Petitioner’s petition for a writ of habeas corpus pursuant
to 28 U.S.C. § 2241 without prejudice.
Discussion
I. Procedural History
In Petitioner’s § 2241 petition, Petitioner challenges the lawfulness of his current detention
and asks the Court to, inter alia, issue a writ of habeas corpus pursuant to 28 U.S.C. § 2241
ordering Respondent to release Petitioner from custody. (Pet., ECF No. 1, PageID.7.)
In an order entered on August 5, 2026, the Court directed Respondent to show cause, within
three business days, why the writ of habeas corpus and other relief requested by Petitioner should
not be granted. (Order, ECF No. 5.) Respondent filed his response on August 10, 2026, (ECF
No. 6).
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II. Relevant Factual Background
On June 29, 2026, Petitioner filed a § 2241 petition challenging his initial detention without
a bond hearing in Mohamed v. Raycraft (Mohamed I), No. 1:26-cv-1959 (W.D. Mich.). In
Mohamed I, the Court denied Petitioner’s petition for a writ of habeas corpus pursuant to 28 U.S.C.
§ 2241 without prejudice. Op. & Jud., Mohamed I, (W.D. Mich. July 15, 2026), (ECF Nos. 9, 10).
In Mohamed I, the Court summarized the relevant factual background as follows:
Petitioner is a native and citizen of Somalia. (Pet., ECF No. 1, PageID.10.) On
August 14, 2024, the United States Citizenship and Immigration Services (USCIS)
terminated Petitioner’s asylum status, stating that his December 2021 federal
conviction constituted an aggravated felony, in violation of INA § 101(a)(43)(B).
(Anderson Decl. ¶ 11, ECF No. 5-1, PageID.25–26.) On August 25, 2025, ICE
arrested Petitioner upon his release from federal prison and placed him at the North
Lake Processing Center. (Id. ¶ 12, PageID.26.)

At that time, the Department of Homeland Security (DHS) charged Petitioner with
removability pursuant to § 237(a)(2)(A)(iii) of the Immigration and Nationality Act
(INA) “for having been convicted of aggravated felony drug trafficking and
conspiracy offenses, in violation of INA §§ 101(a)(43)(B) and (U); and
removability under INA § 237(a)(2)(B) for having been convicted of a violation of
any law or regulation relating to a controlled substance.” (Id. ¶ 13, PageID.26.)

On January 30, 2026, the Detroit Immigration Court ordered Petitioner to be
removed to Somalia. (Id. ¶ 14, PageID.26.) Petitioner did not file an appeal,
“resulting in a final order of removal upon expiration of the appeal period” on
March 1, 2026. (Id.) On June 12, 2026, ICE issued Petitioner a travel document for
Somalia, which expires on September 1, 2026. (Id., ¶ 21, PageID.27.) ICE has
scheduled Petitioner “for a commercial removal flight to Somalia on July 31,
2026.” (Id., ¶ 22, PageID.28.)
Op., Mohamed I, (W.D. Mich. July 15, 2026), (ECF No. 9, PageID.72) (citations omitted). In the
response to Petitioner’s current habeas petition (Mohamed II), Respondent states that Petitioner
was removed from the United States to Somalia on July 31, 2026, and that Petitioner was no longer
in the custody of Respondent. (Resp., ECF No. 6, PageID.20–21, ICE Case Closure Form, ECF
No. 6-1, PageID.23.)
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III. 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).
“Under Article III of the United States Constitution, federal courts have the power to
adjudicate only ‘Cases’ and ‘Controversies.’” Cal. Palms Addiction Recovery Campus, Inc. v.
United States, 158 F.4th 726, 730 (6th Cir. 2025) (quoting Mokdad v. Sessions, 876 F.3d 167, 169
(6th Cir. 2017)). “Part of what Article III requires is that there be a live case or controversy—
‘when the issues presented are no longer live or the parties lack a legally cognizable interest in the
outcome,’ a case becomes moot.” Id. (some internal quotations omitted) (citation omitted). “When
the case-and-controversy requirement is not satisfied, federal courts lack subject-matter
jurisdiction.” Id. (citing Mokdad, 876 F.3d at 170.)
IV. Analysis
In Petitioner’s § 2241 petition, as relief, Petitioner asks the Court to order Respondent to
release Petitioner from custody. (Pet., ECF No. 1, PageID.7.) After initiating this action, Petitioner
was removed from the United States to Somalia and is no longer in Respondent’s custody. (Resp.,
ECF No. 6, PageID.20–21, ICE Case Closure Form, ECF No. 6-1, PageID.23.)
Because the relief sought in Petitioner’s § 2241 petition related to his detention, and he is
no longer detained by Respondent, it appears that the present § 2241 petition is moot. Therefore,
the Court will dismiss the action without prejudice.
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Conclusion
For the reasons discussed above, the Court will enter a judgment dismissing Petitioner’s
petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.

Dated: August 14, 2026 /s/ Paul L. Maloney
Paul L. Maloney
United States District Judge
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