Cavanaugh v. Wyatt Detention Center
- McElroy
- 1:25-cv-08169
- U.S. District Court · Southern District of New York
- 3
In Cavanaugh v. Wyatt Detention Center, Judge McElroy transferred Cavanaugh’s detention challenge because Rhode Island lacked jurisdiction.
Sarah Jane Cavanaugh’s § 2241 petition was transferred out of the District of Rhode Island; Patrick McFarland was substituted as the sole respondent, and Wyatt Detention Facility was terminated as a party.
What happened
In Sarah Jane Cavanaugh v. Wyatt Detention Center, Sarah Cavanaugh asked for immediate release, claiming that her detention violated due process. The government argued that the Rhode Island court lacked jurisdiction and that she had not completed required administrative steps.
The court held that a detention challenge must be directed to the official who has custody of the person challenging detention. Although Cavanaugh was held at a Rhode Island facility, the court found that the Bureau of Prisons’ New York Residential Reentry Management Office remained her custodian. The court therefore did not have jurisdiction and did not address exhaustion.
Judge Mary S. McElroy substituted Patrick McFarland as the only respondent, ended Wyatt Detention Facility’s status as a party, and ordered the case transferred to the U.S. District Court for the Southern District of New York.
The detailed version
- Cavanaugh v. Wyatt Detention Center · No. 1:25-cv-08169
- McElroy
- Sept. 23, 2025
Background
Sarah Jane Cavanaugh filed a petition under 28 U.S.C. § 2241, a procedure used to challenge the legality or execution of a person’s custody. She alleged violations of due process and sought immediate release. The government opposed the petition, arguing that the court lacked jurisdiction and that Cavanaugh had not exhausted her administrative remedies.
The opinion states that Cavanaugh was transferred under the Second Chance Act to Houston House, a private residential reentry center in Pawtucket, Rhode Island, on May 15, 2025. On August 15, she was transferred from Houston House to temporary confinement at the Wyatt Detention Facility in Central Falls, Rhode Island. The Bureau of Prisons’ New York Residential Reentry Management Office retained custodial control over her placement and monitoring.
Jurisdictional Analysis
The court explained that the proper respondent in a habeas case is generally the person who has custody of the petitioner, usually the warden or other official responsible for the facility where the petitioner is held. Because habeas relief operates against the custodian, the court must determine where that custodian is located to determine the proper jurisdiction.
The court found that Cavanaugh’s custodian was not Wyatt Detention Facility. Instead, it identified Patrick McFarland, the manager of the New York Residential Reentry Management Office, as her custodian. Because McFarland was not in the District of Rhode Island, the court concluded that it lacked jurisdiction over the petition.
Because jurisdiction was dispositive, the court did not decide whether Cavanaugh had exhausted her administrative remedies.
Disposition
The court ordered two actions. First, it substituted Residential Reentry Manager Patrick McFarland of the New York Regional Reentry Office as the sole respondent and terminated Wyatt Detention Facility as a party. Second, under 28 U.S.C. § 1631, it ordered the clerk to transfer the action to the U.S. District Court for the Southern District of New York.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.