Zhilun Liu v. Todd M. Lyons, et al.
- Proceeding
- district
- Area
- civil
Analysis
The court reviewed a petition for writ of habeas corpus filed by a federal immigration detainee in the Eastern District of California, which challenged her physical custody at a facility in the Southern District of California. The court ordered the case transferred to the Southern District of California.
| 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 'district of confinement' rule for 28 U.S.C. § 2241 habeas petitions. Under Rumsfeld v. Padilla and the Ninth Circuit's decision in Doe v. Garland, a petitioner challenging present physical custody must file in the district where they are confined. The petitioner's arguments regarding high-level officials and judicial economy do not override the mandatory venue/jurisdictional requirement for core habeas petitions challenging physical custody. The use of 28 U.S.C. § 1631 is the appropriate mechanism to transfer a case to the proper district. |
The order itself: sound — The order correctly identifies the applicable legal standard for § 2241 habeas petitions and applies it to the specific facts of the case. It addresses the petitioner's counter-arguments by reaffirming that the district of confinement rule is mandatory for challenges to physical custody, citing binding Ninth Circuit precedent. The reasoning is concise and directly supports the transfer order.
How this analysis was made · dispute it
inconsistent with cited authorityOpinion
2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 ZHILU LIU, Case No. 1:26-cv-02123-KES-EPG-HC 12 Petitioner, ORDER TRANSFERRING CASE TO THE 13 v. UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF 14 TODD M. LYONS, et al., CALIFORNIA 15 Respondents.
16 17 Petitioner, represented by counsel, is a federal immigration detainee proceeding with a 18 petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241. 19 “Whenever a § 2241 habeas petitioner seeks to challenge his present physical custody 20 within the United States, he should name his warden as respondent and file the petition in the 21 district of confinement.” Rumsfeld v. Padilla, 542 U.S. 426, 447 (2004). The Ninth Circuit has 22 “affirm[ed] the application of the immediate custodian and district of confinement rules to core 23 habeas petitions filed pursuant to 28 U.S.C. § 2241, including those filed by immigrant 24 detainees.” Doe v. Garland, 109 F.4th 1188, 1199 (9th Cir. 2024). 25 Here, Petitioner challenges her present physical custody at the Calixto Detention Facility 26 in Imperial County, California. (ECF No. 1 at 2.) Therefore, jurisdiction lies in the district of 27 confinement, which is the Southern District of California. “Whenever a civil action is filed in a ] | interest of justice, transfer such action or appeal to any other such court . . . in which the action 2 | or appeal could have been brought at the time it was filed or noticed... .” 28 U.S.C. § 1631. 3 On March 18, 2026, the Court ordered Petitioner to show cause why this matter should 4 | not be transferred to the Southern District of California. (ECF No. 4.) That same day, Petitioner 5 | filed a response, arguing that “[w]hile the ‘district of confinement’ rule is the general practice, it 6 | is not jurisdictional in the strictest sense and may yield in appropriate circumstances.” (ECF No. 7 | 5 at 2.) “Petitioner challenges not only the fact of her detention but also the legality of policies 8 | and decisions made by federal officials whose authority extends beyond the Southern District. To 9 | the extent that high-level federal officials are named respondents, the claims are not confined 10 | solely to local custodial authority.” (ECF No. 5 at 3.) Additionally, Petitioner argues that several 11 | factors weigh against transfer, including judicial economy, potential prejudice to Petitioner due 12 | to unnecessary delay, and counsel and case efficiency. 13 The Court does not find Petitioner’s arguments persuasive. The petition challenges 14 | Petitioner’s present physical custody at the Calixto Detention Facility, and this Court would 15 | “err[] in exercising jurisdiction over [a] core habeas petition . . . filed . . . outside the district of [a 16 | petitioner’s] confinement.” Doe, 109 F.4th at 1199. 17 Accordingly, IT IS HEREBY ORDERED that this action is TRANSFERRED to the 18 | United States District Court for the Southern District of California. 19 20 IT IS SO ORDERED. 21} Dated: _ March 19, 2026 [sf Ree ey UNITED STATES MAGISTRATE JUDGE 23 24 25 26 27 28