Jobanjeet Singh v. Warden, Imperial Regional Detention Facility, et al.
- Proceeding
- original
- Outcome
- other — 8.) T
- Area
- civil
- Panel
- Cynthia Ann Bashant (author)
Analysis
The court considered a second habeas petition filed by a pro se immigration detainee challenging his detention after his first petition had been granted and subsequent motions to enforce the resulting judgment had been denied. The court denied the petition as duplicative and without prejudice, and denied the motion to appoint counsel as moot.
| What the court decided | The model |
|---|---|
Petition for Writ of Habeas Corpus denied“Therefore, the Court DENIES the Petition. (ECF No. 1.)” | agree with court The court's decision to deny the petition as duplicative is supported by the recited facts that the petitioner had previously litigated the same issues in a prior case and subsequent motions, and that no new grounds were raised. The finding that the petitioner failed to exhaust administrative remedies further supports the denial. The order correctly identifies the petition as repetitive. |
Motion to Appoint Counsel denied as moot“The Court also DENIES AS MOOT the Motion to Appoint Counsel. (ECF No. 2.)” | agree with court Because the underlying petition was denied, the request for counsel to assist in that petition became moot. This is a standard procedural consequence. |
Action dismissed without prejudice“The Clerk of Court shall enter a judgment dismissing this action without prejudice and close the case file.” | agree with court Dismissing a duplicative petition without prejudice is appropriate because it allows the petitioner to refile if new grounds or exhaustion of administrative remedies are later achieved. It does not bar future claims based on new facts. |
The order itself: sound — The order correctly identifies the petition as duplicative of prior litigation in the same district and notes the lack of new grounds. It also correctly notes the failure to exhaust administrative remedies, which is a prerequisite for federal court review of immigration detention decisions. The reliance on a district court case from another district (W.D. Wash.) for the proposition that duplicative petitions can be dismissed is acceptable, as this is a well-established procedural principle. The order is concise but sufficient for a procedural dismissal.
How this analysis was made · dispute it
record incompleteOpinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOBANJEET SINGH, Case No. 26-cv-04657-BAS-MSB 12 Petitioner, ORDER DENYING PETITION FOR 13 v. WRIT OF HABEAS CORPUS (ECF No. 1) 14 WARDEN, IMPERIAL REGIONAL DETENTION FACILITY, et al., 15 Respondents. 16 17 18 On August 14, 2026, Petitioner Jobanjeet Singh filed a Petition for Writ of Habeas 19 Corpus pursuant to 28 U.S.C. § 2241. (ECF No. 1.) This is Petitioner’s second Petition 20 filed in the District challenging his immigration detention. (See Singh v. Warden, No. 26- 21 cv-00154-BAS-MSB (S.D. Cal. filed Jan. 9, 2026) (“First Petition”).) 22 The First Petition was filed with the assistance of counsel on January 9, 2026. (First 23 Petition, ECF No. 1.) After briefing, the Court granted the First Petition on January 23, 24 2026. (Id., ECF No. 5.) The Court ordered that Petitioner be granted a bond hearing before 25 an Immigration Judge within 14 days. (Id.) The Clerk entered judgment and closed the 26 case. (Id., ECF No. 6.) 27 28 1 On March 11, 2026, Petitioner filed a Motion to Enforce Judgment in the First 2 || Petition. (First Petition, ECF No. 7.) After hearing from the Government, the Court denied 3 ||the Motion. (/d., ECF No. 8.) The Court found that the Government complied with its 4 || earlier order requiring a bond hearing. (/d.) Further, the Court reasoned that Petitioner had 5 || failed to exhaust his administrative remedies. /d.) The Court thus found that appeal to the 6 || Board of Immigration Appeals (“BIA”) “is a necessary prerequisite” before the Court “may 7 || consider any error on the part of the Immigration Judge.” (/d.) 8 Nevertheless, on June 26, 2026, Petitioner filed an Amended Motion to Enforce 9 || Judgment through new counsel. (First Petition, ECF Nos. 11, 12.) The Court denied the 10 || Amended Motion on July 27, 2026, because it improperly sought reconsideration of the 11 || Court’s prior ruling. Ud., ECF No. 16.) 12 About two weeks later, Petitioner filed the present Petition without the assistance of 13 ||counsel. (ECF No. 1.) The Petition was initially assigned to the Honorable James E. 14 || Simmons, Jr., who transferred it to the undersigned on August 17, 2026. (ECF No. 3.) 15 A habeas petition is subject to summary dismissal when it is repetitive or duplicative. 16 || See, e.g., Salas v. Att’y Gen., No. 2:23-cv-01118-TL-TLF, 2023 WL 5826738, at *2 (W.D. 17 || Wash. Aug. 21, 2023). The Petition here provides no new information or grounds for relief 18 || that were not raised in the First Petition, the Motion to Enforce Judgment, or the Amended 19 || Motion to Enforce Judgment. Petitioner has not exhausted his administrative remedies. 20 || (See Pet. § 6(b).) Therefore, the Court DENIES the Petition. (ECF No. 1.) The Court also 21 DENIES AS MOOT the Motion to Appoint Counsel. (ECF No. 2.) 22 The Clerk of Court shall enter a judgment dismissing this action without prejudice 23 || and close the case file. 24 IT IS SO ORDERED. 25 26 DATED: August 18, 2026 yatta Bahar □ 27 Hon. Cynthia Bashant, Chief Judge 28 United States District Court ~_9_