Cavanaugh v. Wyatt Detention Center

Background

Sarah Jane Cavanaugh filed a petition under 28 U.S.C. § 2241, a federal law that permits a court to review certain forms of detention. She filed the petition in the District of Rhode Island on August 25, 2025, while incarcerated at the Wyatt Detention Center in Central Falls, Rhode Island. She named Wyatt Detention Center as the respondent.

The Government opposed the petition and moved to dismiss. It submitted a declaration from Patrick McFarland, who identified himself as Cavanaugh’s custodian in his role as New York Residential Reentry Manager. The District of Rhode Island substituted McFarland as the sole respondent and transferred the case to the Southern District of New York under 28 U.S.C. § 1631.

Jurisdiction and Transfer

The Southern District of New York later ordered the Government to explain why the case should not be transferred back to Rhode Island. The court explained that, for a core habeas petition challenging a person’s present physical confinement, jurisdiction generally lies in the district where the person is confined and requires jurisdiction over the person’s custodian.

In response, the Government stated that Cavanaugh had been moved on September 23, 2025, from Wyatt Detention Center to the satellite prison camp at the Federal Medical Center in Lexington, Kentucky. The Government identified David Paul, the custodian of that facility, as Cavanaugh’s current custodian. It consented to substituting Paul as respondent and requested transfer to the Eastern District of Kentucky. Cavanaugh did not oppose either action.

Ruling

The court determined that the Eastern District of Kentucky was the court that then had jurisdiction to entertain the habeas action. Judge Lewis J. Liman ordered the Clerk to substitute David Paul for the existing respondents and transfer the case to the United States District Court for the Eastern District of Kentucky. The order did not decide whether Cavanaugh was entitled to habeas relief on the merits.