Castillo Lachapel v. Joyce

Background

Francisco Antonio Castillo Lachapel filed a petition asking the federal court to review his immigration detention and expedited-removal proceedings. He named William Joyce, in his official capacity as Acting Field Office Director of the New York Field Office for U.S. Immigration and Customs Enforcement; Kristi Noem, in her official capacity as Secretary of Homeland Security; and Pam Bondi, in her official capacity as Attorney General of the United States.

Castillo Lachapel alleged violations of the Immigration and Nationality Act and the Fifth Amendment. The opinion states that he is a citizen of the Dominican Republic, entered the United States in June 2022, and lives in New York City with his wife and stepson. After a traffic stop in Maine on or about January 17, 2025, Immigration and Customs Enforcement detained him and issued a notice to appear in removal proceedings.

At an immigration hearing on June 4, 2025, an immigration judge granted Immigration and Customs Enforcement’s motion to dismiss the existing removal proceedings because the agency believed Castillo Lachapel was subject to expedited removal. After he left the courtroom, Immigration and Customs Enforcement detained him and personally served him with an expedited-removal order under 8 U.S.C. § 1225(b)(1). Castillo Lachapel then filed this petition.

Events During the Case

After an attorney provided Immigration and Customs Enforcement with evidence that Castillo Lachapel had been physically present in the United States for more than two years, the agency determined that he was not subject to expedited removal. On June 10, 2025, Immigration and Customs Enforcement canceled the expedited-removal order. The agency issued a new notice to appear charging him with being present in the United States without being admitted or paroled and thereby began new removal proceedings under 8 U.S.C. § 1229a. An initial hearing in those proceedings was scheduled for July 1, 2025.

The petition also challenged Castillo Lachapel’s detention. He acknowledged that detention was authorized under 8 U.S.C. § 1226(a) for people in removal proceedings following entry without inspection who, like him, had no criminal history. Immigration and Customs Enforcement was in the process of making a new custody determination, after which he could seek a custody redetermination, commonly called a bond hearing, before an immigration judge.

Court’s Analysis

The court ruled that Castillo Lachapel’s claims concerning expedited removal and the related removal proceedings were moot because Immigration and Customs Enforcement had canceled the expedited-removal order. A claim is moot when circumstances have eliminated the live dispute that the court could resolve.

For the detention challenge, the court applied the rule that a habeas petitioner ordinarily must exhaust available administrative remedies before seeking federal court intervention. Although the statute governing this type of petition does not expressly require exhaustion, the court explained that courts in the circuit generally require it as a prudential matter in immigration-detention cases.

The court concluded that Castillo Lachapel’s possible custody determination and bond hearing could provide the release he sought. It therefore exercised its discretion to require him to pursue those avenues before seeking judicial relief. The court stated that this ruling did not prevent him from later seeking federal review of his Fifth Amendment challenge to discretionary detention. If he remained detained after a bond hearing and any appeal to the Board of Immigration Appeals, he could file another petition.

Disposition

Judge Jennifer H. Rearden denied the petition for a writ of habeas corpus without prejudice and directed the Clerk of Court to close the case. The opinion did not decide the underlying merits of Castillo Lachapel’s constitutional or statutory detention claims.