Unreported / Non-Citable
Background
Adam Mahmud Abdella, proceeding without counsel, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241. He challenged his detention after being taken into immigration custody on February 19, 2026.
Abdella was confined at the IAH Secure Adult Detention Facility in Livingston, Texas, when he filed the petition and remained there when the court ruled. Livingston is in Polk County, within the Lufkin Division of the Eastern District of Texas, but the petition was inadvertently filed in the court’s Beaumont Division.
The Court’s Holding
The court held that jurisdiction over Abdella’s § 2241 petition was proper in the Eastern District of Texas because a petition challenging present physical confinement generally must be brought where the petitioner or custodian is located. Because Abdella was confined in Livingston, however, the Lufkin Division was the appropriate division within the district.
Applying 28 U.S.C. § 1404(a), the court concluded that transfer served the convenience of the parties and witnesses and the interest of justice. It reasoned that records and witnesses concerning Abdella’s confinement would most likely be located in the Lufkin Division and ordered the clerk to transfer the action there.
Key Takeaways
- A § 2241 petition challenging present physical confinement generally belongs in the district where the petitioner is confined.
- Abdella’s confinement in Livingston placed the matter within the Eastern District of Texas’s Lufkin Division, not its Beaumont Division.
- The court transferred the case under § 1404(a) without deciding the merits of Abdella’s challenge to his immigration detention.
Why It Matters
The order illustrates that filing a habeas petition in the correct federal district does not necessarily place it in the most appropriate division. Courts may transfer a case within the district when the petitioner, relevant records, and likely witnesses are located in another division.
The ruling is procedural only: it sends Abdella’s petition to the Lufkin Division for further proceedings and does not determine whether his immigration detention is lawful or whether he is subject to removal.