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S.D.N.Y.Procedural orderFiled Dec. 3, 2025

Liang v. Genalo

Judge
Rochon
Docket
1:25-cv-09980
Court
U.S. District Court · Southern District of New York
Pages
2
HabeasCivil Procedure
In one sentence

In Liang v. Genalo, Judge Rochon recorded the petition’s email receipt time and directed termination of the pending motion.

Who this affects

The petitioner, the government, and the Clerk of Court were affected by the order concerning the petition’s filing time and termination of the pending motion.

What happened

In Liang v. Genalo, the government asked the court to determine the exact time a next friend emailed the petitioner’s habeas petition on December 1, 2025. The government said that timing could affect whether this court was the proper venue for the case.

The court was informed that its Pro Se Intake Unit received the petition by email at 9:56 p.m. on December 1, 2025. The court also directed the Clerk of Court to terminate the pending motion at Docket No. 3.

Judge Jennifer L. Rochon’s order resolved the filing-time request and did not decide the habeas petition’s underlying claims or state whether venue was proper.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Liang v. Genalo · No. 1:25-cv-09980
Judge
Rochon
Date
Dec. 3, 2025

Background

A next friend filed a habeas petition for the petitioner on December 1, 2025. The government asked the court to docket the exact time the petition was received, including any email transmitting the petition, so the government could evaluate whether venue was proper. The government explained that habeas jurisdiction for a challenge to present physical custody generally depends on the petitioner’s location when the petition is filed.

Court’s action

The court was informed by the Clerk of Court that the Pro Se Intake Unit received the petition by email at 9:56 p.m. on Monday, December 1, 2025. The court then directed the Clerk of Court to terminate the pending motion at Docket No. 3.

Effect of the order

Judge Jennifer L. Rochon’s order addressed the petition’s receipt time and the pending motion’s docket status. The excerpt does not state that the court granted or denied the government’s request, decide whether venue was proper, or reach the merits of the habeas petition.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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