Case Name in Immigration Case - Unavailable

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Juan A.L.C.,
Petitioner,
v.
Pamela Bondi, Attorney General; Kristi
Noem, Secretary, U.S. Department of
Homeland Security; Todd M. Lyons,
Acting Director of Immigration and
Customs Enforcement; and David
Easterwood, Acting Director, St. Paul
Field Office Immigration and Customs
Enforcement,
Respondents.
Civil No. 26-1367 (DWF/LIB)
MEMORANDUM
OPINION AND ORDER
INTRODUCTION
This matter is before the Court on Petitioner Juan A.L.C.’s petition for a writ of
habeas corpus (the “Petition”). (Doc. No. 1.) Respondents filed a response asserting that
Petitioner was released from detention, so the Petition is now moot. (Doc. No. 6.) In his
reply, Petitioner confirms that he was released but asks the Court to adjudicate his
Petition because it falls under an exception to mootness. (Doc. No. 7.) For the reasons
set forth below, the Court denies the Petition as moot and dismisses this action without
prejudice.
BACKGROUND
Petitioner is a citizen of El Salvador and resident of Richfield, Minnesota. (Doc.
No. 1 ¶¶ 7, 12.) He has lived in the United States for approximately twenty years. (Id.
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¶ 12.) He has a valid work permit and does not have a final order of removal. (Id. ¶ 13.)
On February 11, 2026, U.S. Immigration and Customs Enforcement (“ICE”) agents
arrested Petitioner while he was waiting for food at a restaurant. (Id. ¶ 15.) Later that
day, Respondents released Petitioner from their custody. (Doc. No. 6-1.)
Also on February 11, 2026, before learning that Petitioner had been released,
Petitioner’s counsel filed the Petition. (Doc. No. 1 at 18.) They alleged that Petitioner’s
detention violated the Due Process Clause of the Fifth Amendment, the Immigration and
Nationality Act, and the Administrative Procedure Act. (Id. ¶¶ 30-46.) Respondents
assert that the Petition is moot because Petitioner was released from custody. (See Doc.
No. 6.) Petitioner argues that the Petition is not moot because Respondents are free to re-
detain him at any time under the same theory and there is a reasonable expectation that he
will be arrested again under the same theory. (Doc. No. 7.) The Court asked for
additional briefing on whether Petitioner is subject to any continuing collateral
consequences of his detention, such as a bond or release conditions. (Doc. Nos. 8, 11.)
Petitioner submitted a status report confirming that he was released without any
continuing collateral conditions. (Doc. No. 12.)
DISCUSSION
Federal courts only have jurisdiction to hear “Cases” or “Controversies” under
Article III of the Constitution. U.S. Const. art. III, § 2. As such, federal courts may only
hear cases where there is a live case or controversy and the parties have a legally
cognizable interest in the outcome. See U.S. Parole Comm’n v. Geraghty, 445 U.S. 388,
395-96 (1980). If there is no longer a live controversy or legally cognizable interest, the
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case becomes moot, meaning the court no longer has jurisdiction to hear it. See id. A
petition for writ of habeas corpus becomes moot after the petitioner is released from
detention unless: (1) there are continuing collateral consequences of the detention;
(2) the issue is capable of repetition yet evading review; (3) the respondent voluntarily
ceases the allegedly illegal detention but is free to resume it at any time; or (4) it is a
properly certified class action. See Kargbo v. Brott, No. 15-cv-2713, 2016 WL 3676162,
at *2 (D. Minn. July 6, 2016); Mohamed v. Lynch, No. 15-cv-2726, 2016 WL 563164,
at *3-4 (D. Minn. Jan. 26, 2016) (citing Spencer v. Kemna, 523 U.S. 1, 7 (1998)), report
and recommendation adopted, 2016 WL 593512 (D. Minn. Feb. 12, 2016).
This case does not fit any of the four exceptions to mootness. First, Petitioner
confirmed that he is not subject to any continuing collateral consequences as a result of
his February 11th detention. (See Doc. No. 12.)
Second, Petitioner’s detention does not fit the “capable of repetition yet evading
review” exception. This exception is limited to situations where: “(1) the challenged
action was in its duration too short to be fully litigated prior to its cessation or expiration,
and (2) there [is] a reasonable expectation that the same complaining party would be
subjected to the same action again.” Murphy v. Hunt, 455 U.S. 478, 482 (1982) (per
curiam) (quoting Weinstein v. Bradford, 423 U.S. 147, 149 (1975) (per curiam)). A
reasonable expectation is more than “a mere physical or theoretical possibility.” Id.
Rather, there must be “a demonstrated probability that the same controversy will recur.”
Id. (citation modified).
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Petitioner has not shown a reasonable expectation that he will be detained again.
It is true that a significant number of noncitizens have been arrested and detained by ICE
during Operation Metro Surge. In late February, the Department of Homeland Security
claimed it had arrested over four thousand people during the operation. See Federal
Officials: Fewer Than 1,000 Immigration Agents Remain in Minnesota, MPR News
(Feb. 25, 2026, at 14:00 CT), https://www.mprnews.org/story/2026/02/25/federal-
officials-fewer-than-1000-immigration-agents-remain-minnesota. The Court has felt that
impact. As of March 1, 2026, over a thousand immigration-related habeas petitions have
been filed in this District. That number is staggering when compared to prior years:
12 in 2024 and 130 in 2025.
However, the number of ICE agents in Minnesota and daily arrests have decreased
in the last few weeks. See Decline in New Filings Coincides with ICE Reduction
Announcement, But Courts Still Busy, MPR News (Mar. 1, 2026, at 10:55 CT),
https://www.mprnews.org/story/2026/03/01/new-ice-filings-decline-but-courts-still-busy;
Jake Steinberg, Kyeland Jackson & Bryan Brussee, As ICE Draws Down in Minnesota,
Data Illustrates Intensity of Its Surge Here, Minn. Star Trib. (Feb. 22, 2026),
https://www.startribune.com/is-ice-really-pulling-out-of-minnesota-observer-data-tells-a-
complicated-story/601580496. The sheer volume of arrests certainly makes this case a
closer call. But on the present record, given the changing circumstances, the Court
cannot find a reasonable expectation that Petitioner will be re-detained.
Third, Respondents are not free to resume detention of Petitioner at any time.
Presumably, to re-detain Petitioner, Respondents would need a legal basis to detain him.
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Additionally, there is nothing in the record that suggests that Respondents released
Petitioner simply to avoid court review of the Petition. See Mohamed, 2016 WL 563164,
at *4.
Lastly, this case is not a certified class action. Thus, there is no applicable
exception to the mootness doctrine. The Court therefore lacks jurisdiction to hear the
Petition and dismisses this action without prejudice.
ORDER
Based on the foregoing and the record in this case, IT IS HEREBY ORDERED
that:
1. 	Petitioner’s petition for writ of habeas corpus (Doc. No. [1]) is DENIED
AS MOOT.
2. 	This action is DISMISSED WITHOUT PREJUDICE for lack of
jurisdiction.
LET JUDGMENT BE ENTERED ACCORDINGLY.
Dated: March 9, 2026 	s/Donovan W. Frank
DONOVAN W. FRANK
United States District Judge
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