Reported / Citable
Background
Selvin Daniel Estuardo Munoz Leal, a non-citizen detained in immigration custody, filed an amended habeas corpus petition challenging his ongoing detention. The court had previously ordered respondents to address the effect of a nationwide class action on Petitioner’s case.
The relevant class action, Immigration Center for Women and Children v. Noem (C.D. Cal. 2025), concerns deferred action relief for non-citizens approved for U-visas while on the waiting list. That court granted a preliminary injunction providing nationwide relief. Petitioner is a member of this class. Despite the court’s specific order, respondents filed a submission that failed to address whether Petitioner had been granted deferred action or how the class action affected his detention and removal proceedings.
Petitioner subsequently submitted evidence establishing his approval for a U-visa with deferred action status. The respondents did not contest his class membership or the nationwide scope of the preliminary injunction.
The Court’s Holding
The court granted Petitioner’s Amended Petition for a Writ of Habeas Corpus and denied Respondents’ Motion to Dismiss and Motion for Summary Judgment. The court found that Petitioner had shown entitlement to release based on his approved U-visa status with deferred action on his immigration file.
The court found the reasoning in the ICWC class action decision persuasive, even noting that release would be warranted if Petitioner remained on the waiting list for U-visa deferred action. The respondents’ non-responsive submission and failure to address material facts, combined with Petitioner’s documentary evidence of U-visa approval, persuaded the court of his right to release.
The court ordered that Petitioner be released in a mutually agreed public location within three days, with respondents providing his counsel at least four hours’ written notice of the exact time and location. The parties must provide a status update by July 1, 2026, and a joint status update addressing the case’s potential closure by July 10, 2026.
Key Takeaways
- A non-citizen approved for a U-visa with deferred action status is entitled to habeas corpus relief from immigration detention.
- Membership in a nationwide class action obtaining a preliminary injunction provides a basis for individual habeas relief in parallel proceedings.
- Failure to adequately respond to court orders regarding class action effects can result in adverse findings and default liability.
Why It Matters
This decision directly affects all members of the ICWC class action nationwide—potentially thousands of non-citizens approved for U-visas while awaiting status finalization. The ruling establishes that U-visa deferred action status, even while on the waiting list, provides an independent basis for release from immigration detention and bars removal proceedings.
The decision demonstrates the practical power of class action preliminary injunctions to disrupt government detention and removal procedures across multiple districts simultaneously. It also reflects judicial impatience with non-responsive government filings that ignore material facts and fail to engage with controlling class action precedent.