Cavanaugh v. Wyatt Detention Center
- Lewis Liman
- 1:25-cv-08169
- U.S. District Court · Southern District of New York
- 3
Cavanaugh v. Wyatt Detention Center: Judge Liman ordered Cavanaugh to respond on transferring her habeas case to Kentucky and closed a pending motion.
Sarah Cavanaugh, who must respond about whether the case should proceed in the Eastern District of Kentucky; the Government, whose response deadline was postponed; and the respondents potentially affected by a transfer and substitution of the Kentucky warden.
What happened
In Cavanaugh v. Wyatt Detention Center et al., Sarah Cavanaugh, representing herself, filed a petition challenging her confinement conditions and seeking transfer to a residential reentry center. She was later moved to a federal facility in Kentucky.
The Government argued that the Southern District of New York lacks authority over the petition because Cavanaugh is confined in Kentucky and her current custodian is there. It asked the court to transfer the case to the Eastern District of Kentucky, where Cavanaugh could pursue the petition against the warden there.
Judge Lewis J. Liman ordered Cavanaugh to state within two weeks whether she agrees to venue in Kentucky rather than Rhode Island. The court also closed the motion at Docket No. 22 and postponed the Government’s response deadline indefinitely; the order did not itself state that the case was transferred.
The detailed version
- Cavanaugh v. Wyatt Detention Center · No. 1:25-cv-08169
- Lewis Liman
- Oct. 28, 2025
Background
Sarah Cavanaugh filed a petition under 28 U.S.C. § 2241, a federal law allowing a person to challenge certain aspects of federal custody. The opinion states that Cavanaugh was representing herself. She challenged her conditions of confinement and asked the court to order the Bureau of Prisons to transfer her to Houston House, a residential reentry center in Pawtucket, Rhode Island.
Cavanaugh initially filed the petition in the District of Rhode Island while she was held at the Wyatt Detention Facility. She was later transferred to the Federal Medical Center in Lexington, Kentucky. The Government identified Warden David Paul in Kentucky as her current custodian.
Government’s position
The Government argued that the Southern District of New York lacks subject-matter jurisdiction—the court’s legal authority to hear the case—under the immediate-custodian rule. Under that rule, a person challenging present physical custody generally must name the official with immediate physical custody and file the petition in the federal district where the person is confined. The Government therefore asked the court to transfer the case to the Eastern District of Kentucky and said it would consent to substituting Warden Paul as the respondent.
Court’s order
The court directed Cavanaugh to respond within two weeks after receiving the order and to state whether she consents to venue in the Eastern District of Kentucky instead of the District of Rhode Island. The court directed the Clerk to mail the order to Cavanaugh and directed the Government to serve her and file proof of service. The court adjourned the Government’s deadline to respond to the motion indefinitely and directed the Clerk to close the motion at Docket No. 22. The text does not state that the court granted or denied the requested transfer, or that it actually transferred the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.