Reported / Citable
Background
Daffton Anthony Bloomfield, a Jamaican citizen and transgender woman, is detained by Immigration and Customs Enforcement at the Houston Contract Detention Facility. Through counsel, she filed a Section 2241 habeas petition, a motion for a preliminary injunction, and later a temporary-restraining-order motion.
Bloomfield alleged that she was held in an all-male dorm, sexually abused and nearly daily harassed, and denied adequate medical care and medication. She is subject to a final removal order but has received deferral of removal to Jamaica based on a finding that she would more likely than not face torture or persecution there. After more than eight months of post-removal-order detention, she also invoked Zadvydas v. Davis, arguing that removal was not significantly likely in the reasonably foreseeable future.
The government advised that it intended to remove Bloomfield to Rwanda on August 26, 2026. Bloomfield responded with a USCIS determination stating that she had established that she was more likely than not to be persecuted in Rwanda.
The Court’s Holding
Judge Andrew S. Hanen enjoined the respondents from transferring or removing Bloomfield from the Southern District of Texas while the court considers her motions. The court concluded that preserving the status quo was warranted by her submissions indicating that removal to Rwanda may be impermissible in light of USCIS’s persecution finding.
The court did not decide the merits of Bloomfield’s habeas, detention, medical-care, or removal claims. Instead, it held that it could issue a status-quo order while determining its own jurisdiction and, if appropriate, adjudicating the substantive claims. The court relied on its authority to determine jurisdiction and to preserve existing conditions pending that determination.
The order also kept in effect an earlier requirement that the government give five days’ notice before any transfer or removal. It required that notice to be filed on the docket, explain why the government believes the movement is necessary, and address why it should not be stayed pending further proceedings.
Key Takeaways
- The order temporarily bars ICE from transferring or removing Bloomfield from the Southern District of Texas.
- The court entered the injunction to preserve its ability to decide jurisdiction and the pending motions, not as a final ruling on the merits.
- Any proposed transfer or removal remains subject to five days’ written, docketed notice with a stated justification.
Why It Matters
The order shows a district court using a temporary status-quo injunction in an immigration-detention habeas case where a planned third-country removal appears to conflict with an agency persecution determination. It preserves the court’s ability to review the matter before the government carries out the proposed movement.