Caceres Molina v. Joyce
- Lewis Kaplan
- 1:25-cv-01844
- U.S. District Court · Southern District of New York
- 18
In Caceres Molina v. Joyce, Judge Kaplan denied the Government’s motion to dismiss or transfer, holding venue was proper in the Southern District of New York.
Milton Caceres Molina may continue litigating his Fifth Amendment and Administrative Procedure Act claims in the Southern District of New York. The Government’s request to dismiss or transfer the case for improper venue was denied; the opinion did not decide whether Caceres’s underlying claims are valid.
What happened
In Caceres Molina v. Joyce, Milton Caceres Molina, who is detained by Immigration and Customs Enforcement in Louisiana, challenged his detention without a neutral bond hearing. He brought claims under the Fifth Amendment and the Administrative Procedure Act.
The Government argued that the case was a core challenge to physical confinement and therefore had to be filed where Caceres was detained. It asked the court to dismiss the case for improper venue or transfer it to the Western District of Louisiana.
Judge Lewis A. Kaplan denied the Government’s motion. He ruled that success on Caceres’s claims would not necessarily require his release or shorten his detention, so the district-of-confinement rule did not apply. He also found that venue was proper in the Southern District of New York because relevant custody decisions were made at the New York Field Office. The ruling addressed venue, not whether Caceres’s constitutional or administrative-law claims ultimately succeed.
The detailed version
- Caceres Molina v. Joyce · No. 1:25-cv-01844
- Lewis Kaplan
- Aug. 5, 2025
Background
Milton Caceres Molina, also identified in the caption as Milton Canales Molina, is detained by U.S. Immigration and Customs Enforcement at the Central Louisiana ICE Processing Center. He alleges that he has been detained for more than 37 months without a bond hearing before a neutral decision-maker. He claims that this violates the Fifth Amendment’s Due Process Clause and that ICE violated the Administrative Procedure Act by failing to follow custody-review requirements and its own policy favoring release of people granted protection under the Convention Against Torture.
Caceres seeks a bond hearing at which the Government would have to prove by clear and convincing evidence that continued detention is necessary because of danger to the public or risk of flight that cannot be addressed through alternatives to detention or reasonable bond. He also asks the court to set aside ICE’s November 2024 denial of discretionary release.
The Government’s Motion
The Government moved to dismiss the case for improper venue or transfer it to the Western District of Louisiana, where Caceres is detained. It argued that Caceres’s claims were a “core” habeas challenge to his present physical confinement. Under the district-of-confinement rule, such a case generally must be brought in the federal district where the person is confined.
Court’s Analysis
Judge Lewis A. Kaplan applied the standard from Preiser v. Rodriguez and related Supreme Court decisions. Under that standard, a claim falls within the core of habeas proceedings when success would necessarily show that the person’s confinement or its duration is invalid. The Supreme Court’s 2025 decision in Trump v. J. G. G. confirmed that this rule can apply in immigration cases, even when the plaintiff does not formally request release.
The court nevertheless concluded that Caceres’s claims were not core habeas claims. Caceres requested a bond hearing, not an order requiring his release or shortening his detention. A favorable ruling would require immigration officials to decide whether he should remain detained; it would not necessarily result in his release. Nor would it necessarily invalidate the statutory basis for his detention under 8 U.S.C. § 1231. Therefore, the district-of-confinement rule did not require Caceres to sue in the district where he was detained.
The court then applied the venue rules for federal officers sued in their official capacities. It found that venue was proper in the Southern District of New York because William Joyce performed official duties at ICE’s New York Field Office, and because that office was responsible for decisions about Caceres’s custody, including the initial detention decision and the decision to continue detaining him.
Disposition
The court denied the Government’s motion to dismiss or transfer the action on the basis of allegedly improper venue. The opinion did not decide the merits of Caceres’s Fifth Amendment or Administrative Procedure Act claims.
Read the full 18-page opinion on CourtListener, the free public archive maintained by the Free Law Project.