Original Date Announced

Immigration and Customs Enforcement (ICE) has adopted a practice of rapidly moving individuals in detention out of judicial districts in which they were initially detained, transferring them largely to detention centers in Texas and Louisiana, where immigration appeals and habeas petitions challenging detention will be heard by the conservative Fifth Circuit Court of Appeals. Several courts overseeing individual cases have ordered that these individuals' cases be heard in the district where the individuals filed their habeas petitioners, and judges in several districts have imposed orders preventing the mass rapid transfer of detainees out of state before they can secure legal representation. However, federal courts have found that ICE has repeatedly violated such orders. Some have ordered individual noncitizens returned to their districts and other courts have threatened to initiate criminal contempt proceedings against ICE officials.

Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security

Trump 2.0 [ID #2249]

Subsequent Trump and Court Action

2025.04.01 Opinion and Order Finding Jurisdiction - M.K. v. Joyce

Judge Michael Farbiarz issued an order and opinion finding that the New Jersey District Court has habeas jurisdiction over Mahmoud Khalil's case. M.K. v. Joyce, No. 2:25-cv-01963 (D.N.J.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.05.06 Memorandum Opinion on Habeas Jurisdiction - Suri v. Trump

In the case of Badar Khan Suri, a postdoctoral fellow at Georgetown University who ICE detained and attempted to deport for his pro-Palestinian activism, Judge Patricial Toliver Giles of the Eastern District of Virginia found that she had habeas jurisdiction over Khan Suri's case, despite ICE's transfer of Suri to a detention center in Texas. Judge Giles noted that Dr. Khan Suri's Notice to Appear, which was generated while he was still in Virginia, stated that his current address was that of the Prarieland Detention Center in the Northern District of Texas. Judge Giles held that because Khan Suri's habeas petition was filed while he was still in Virginia, jurisdiction was proper there, and that the government's argument that the government-generated Notice to Appear contained the address of the Texas detention center was "irrelevant because at the time the petition was filed, Petitioner was not in the Northern District of Texas." Judge Giles also noted that several exceptions to the traditional district of confinement rule for habeas jurisdiction applied in Khan Suri's case. Suri v. Trump, 1:25-cv-00480, (E.D. Va.).

Link to case here. See litigation note above.

Subsequent Trump and Court Action

Reported 2026.01.28: ICE illegally detaining, moving Minnesota children to Texas faster than courts can respond - MPR News

Minnesota Public Radio reports on "an accelerating trend of what [immigration attorneys] describe[] as ICE agents sending children and adults with legal immigration status out of state to avoid dealing with accountability from the federal court system . . . [S]everal lawyers told MPR News the trend of illegally detaining immigrants, including young children and shipping them out of state has been widespread." According to one lawyer, "[s]ince [Operation] Metro Surge came, they've been moving them all out to Texas . . . within 24 hours."

Subsequent Trump and Court Action

2026.02.06 Order Granting Writ of Habeas Corpus - Vigil Rodriguez v. Wesling

Judge Nathaniel Gorton, Senior U.S. District Judge for the Federal District of Massachusetts, granted a writ of habeas corpus and ordered a bond hearing under 8 U.S.C. § 1226. In doing so, he noted that "petitioner was impermissibly transferred outside the jurisdiction of this Court . . . Petitioner may remain in that location pending his bond hearing but any future violations of this Court's standing order in this case or other habeas cases will result in the imposition of sanctions." Vigil Rodriguez v. Wesling, 1:26-cv-10269, (D. Mass.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.26 Opinion and Order - Rahmonov v. Bondi

In granting a writ of habeas corpus to a noncitizen from Uzbekistan, Judge Donovan Frank of the U.S. District Court for the District of Minnesota noted that "[b]ased on Petitioner's allegation that he was in Minnesota at the time of filing, it appears that Respondents violated the Court’s order enjoining Respondents from moving Petitioner out of Minnesota while this action is pending. The Court will not order contempt proceedings at this time, so long as Petitioner is promptly returned to Minnesota and released." Rahmonov v. Bondi, 0:26-cv-00955, (D. Minn.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.03.02 Opinion - Kumar v. Soto

Judge Michael Farbiarz of the District of New Jersey issued an order granting a writ of habeas corpus to Baljinder Kumar, finding that despite a January 26, 2026, order prohibiting Kumar's the removal from the district, ICE transferred him to a detention center in Texas. While the government characterized the transfer as "inadvertent" due to administrative oversight, the Court identified 17 similar violations of no-transfer orders occurring in the district since December 2025. "This means that no-transfer orders are being violated at a rate of around three every two weeks."

To ensure future compliance and avoid the "last resort" of criminal contempt proceedings, Judge Farbiarz held that "going forward, in all of its immigration-habeas cases, the undersigned's no-transfer injunctions will include an order" requiring both the U.S. Attorney’s Office and ICE to promptly file declarations under penalty of perjury for every new no-transfer injunction issued. These declarations, signed by senior leadership, must confirm that the specific injunction was received, conveyed to appropriate personnel, and accompanied by written legal advice regarding the obligation to comply.

Judge Farbiarz indicated that "if there are future violations of a no-transfer injunction . . . the ball will start off at a different place, closer to the 'last resort' of possible criminal contempt proceeding." Kumar v. Soto, 26-cv-00777 (D.N.J.).

Link to case here. See litigation note above.