(HC) Randhawa v. Warden of the Otay Mesa Detention Center Detention Facility

District Court, S.D. California · 3:25-cv-02444 · 2025-09-16 · Unknown

Proceeding: district
Area: civil
Panel: Stanley Albert Boone (author)

Analysis

A model's reading — qwen3.8-27b, prompt own-v1, 2026-10-13T20:54Z · confidence high

The court reviewed a pro se habeas corpus petition filed by a federal immigration detainee in the Eastern District of California, determining that venue was improper because the petitioner is confined in the Southern District of California. The court ordered the case transferred to the United States District Court for the Southern District of California under 28 U.S.C. § 1631.

What the court decided	The model
Transfer of case to the United States District Court for the Southern District of California “IT IS HEREBY ORDERED that this action is TRANSFERRED to the United States District Court for the Southern District of California.”	agree with court The court correctly applied the 'immediate custodian' and 'district of confinement' rules for § 2241 habeas petitions. Since the petitioner is physically confined in San Diego (S.D. Cal.), the E.D. Cal. lacked proper venue. Under 28 U.S.C. § 1631, transfer is the appropriate remedy when an action is filed in a court without jurisdiction or venue, provided it is in the interest of justice. The court’s decision to transfer rather than dismiss is consistent with statutory authority and case law.
Motion for appointment of counsel not ruled upon “This Court has not ruled on the motion for appointment of counsel. (ECF No. 2.)”	agree with court The court explicitly noted it did not rule on this motion. This is a procedural status update rather than a substantive decision, so no legal error is apparent in the order itself.

What the court decided

The model

Transfer of case to the United States District Court for the Southern District of California

“IT IS HEREBY ORDERED that this action is TRANSFERRED to the United States District Court for the Southern District of California.”

agree with court
The court correctly applied the 'immediate custodian' and 'district of confinement' rules for § 2241 habeas petitions. Since the petitioner is physically confined in San Diego (S.D. Cal.), the E.D. Cal. lacked proper venue. Under 28 U.S.C. § 1631, transfer is the appropriate remedy when an action is filed in a court without jurisdiction or venue, provided it is in the interest of justice. The court’s decision to transfer rather than dismiss is consistent with statutory authority and case law.

Motion for appointment of counsel not ruled upon

“This Court has not ruled on the motion for appointment of counsel. (ECF No. 2.)”

agree with court
The court explicitly noted it did not rule on this motion. This is a procedural status update rather than a substantive decision, so no legal error is apparent in the order itself.

The order itself: sound — The order is procedurally sound. It correctly identifies the venue requirement for § 2241 petitions based on the district of confinement, cites binding Supreme Court and Ninth Circuit authority, and applies the correct statutory mechanism (28 U.S.C. § 1631) for transfer. The reasoning is concise but sufficient for a procedural transfer order.

How this analysis was made · dispute it

inconsistent with cited authority

Opinion

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 JASMEET SINGH RANDHAWA, Case No. 1:25-cv-01201-SAB-HC 12 Petitioner, ORDER TRANSFERRING CASE TO THE 13 v. UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF 14 WARDEN OF THE OTAY MESA CALIFORNIA DETENTION FACILITY, et al., 15 Respondents. 16 17 18 Petitioner is a federal immigration detainee proceeding pro se with a petition for writ of 19 habeas corpus pursuant to 28 U.S.C. § 2241. 20 “Whenever a § 2241 habeas petitioner seeks to challenge his present physical custody 21 within the United States, he should name his warden as respondent and file the petition in the 22 district of confinement.” Rumsfeld v. Padilla, 542 U.S. 426, 447 (2004). The Ninth Circuit has 23 “affirm[ed] the application of the immediate custodian and district of confinement rules to core 24 habeas petitions filed pursuant to 28 U.S.C. § 2241, including those filed by immigrant 25 detainees.” Doe v. Garland, 109 F.4th 1188, 1199 (9th Cir. 2024). 26 Here, Petitioner challenges his present physical custody at the Otay Mesa Detention 27 Center in San Diego, California. (ECF No. 1 at 2.) Therefore, venue is proper in the district of 1 | court . . . and that court finds that there is a want of jurisdiction, the court shall, if it is in the 2 | interest of justice, transfer such action or appeal to any other such court . . . in which the action 3 | or appeal could have been brought at the time it was filed or noticed .. . .” 28 U.S.C. § 1631. 4 | Accordingly, rather than dismissal, the Court finds that transfer of the petition to the United 5 | States District Court of the Southern District of California is appropriate in the interest of justice. 6 Accordingly, IT IS HEREBY ORDERED that this action is TRANSFERRED to the 7 | United States District Court for the Southern District of California. This Court has not ruled on 8 | the motion for appointment of counsel. (ECF No. 2.) 9 10 IT IS SO ORDERED. FA. Se 11 | Dated: _ September 16, 2025 " STANLEY A. BOONE 12 United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28