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Phan v. Department of Homeland Security

No. 1:25-cv-11924 District · Decided Decided
Court
Federal Court
mad
Judge
Brian E. Murphy 46
Decided
Aug 4, 2025
Filed
Jul 7, 2025
Judge (CL)
Brian E. Murphy 46
Filed (CL)
Jul 7, 2025
CL Status
terminated

Case Overview

8 immigrants currently housed at a U.S. Naval Base in Djibouti at risk of being deported to South Sudan filed a petition for writ of habeas corpus and are requesting the court prevent the Trump administration from removing them to South Sudan.


The Application

History

The petitioners, held at a U.S. Naval Base in Djibouti, fall within government custody and habeas corpus jurisdiction; their proposed removal to South Sudan, where they lack citizenship, raises statutory and constitutional questions about compliance with removal procedures and protection against persecution or torture.

The Conclusion

The court issued a decision on the merits of the habeas petition, addressing the government's authority to remove the detainees to a third country and the constitutional or statutory protections available to petitioners in military custody.

Outcome History (3)

  1. Jul 4, 2025 District
    Transferred Unresolved

    Case transferred to the USDC for the District of Massachusetts.

  2. Jul 4, 2025 District
    Stay granted Partial relief

    Administrative stay entered to allow the government to respond to the TRO motion.

  3. Aug 4, 2025 District
    Voluntarily dismissed Settled Final

    Notice of voluntary dismissal by all plaintiffs.

Federal Court TMR-93e2e77a Removal to Third Country May 18, 2026

Case Analysis

Issue

Whether the government may remove alien detainees to a third country under executive authority, and whether such removal violates the habeas corpus rights or due process protections of immigrants detained at a U.S. military facility.

Rule

The habeas corpus statute (28 U.S.C. § 2241) protects persons held in custody within U.S. jurisdiction; the Immigration and Nationality Act governs removal procedures and requires compliance with statutory processes; due process protections apply to aliens in U.S. custody.

Analysis

The petitioners, held at a U.S. Naval Base in Djibouti, fall within government custody and habeas corpus jurisdiction; their proposed removal to South Sudan, where they lack citizenship, raises statutory and constitutional questions about compliance with removal procedures and protection against persecution or torture.

Conclusion

The court issued a decision on the merits of the habeas petition, addressing the government's authority to remove the detainees to a third country and the constitutional or statutory protections available to petitioners in military custody.

Overview

8 immigrants currently housed at a U.S. Naval Base in Djibouti at risk of being deported to South Sudan filed a petition for writ of habeas corpus and are requesting the court prevent the Trump administration from removing them to South Sudan.

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