S.R. v. Immigration and Customs Enforcement
Luis S.R. v. Immigration and Customs Enforcement; Eric Klang, in his official capacity as Sheriff of Crow Wing County, Minnesota; David Easterwood, in his official capacity as Acting Field Office Director of the Saint Paul Field Office, Enforcement and Removal Operations, U.S. Immigration & Customs Enforcement; Todd Lyons, in his official capacity as Acting Director of U.S. Immigration and Customs Enforcement; Markwayne Mullin, in his official capacity as U.S. Secretary of Homeland Security; and Pamela Bondi, in her official capacity as Attorney General of the United States
- Jerry Blackwell
- 0:26-cv-01482
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Luis S.R. v. ICE, Judge Blackwell denied the petition for release from immigration detention, accepting a magistrate judge's recommendation without objection.
People held in immigration detention who seek release by challenging the legality of their confinement in federal court, particularly those detained within the jurisdiction of ICE's Saint Paul Field Office or held at Crow Wing County facilities.
What happened
In Luis S.R. v. Immigration and Customs Enforcement, a person identified only as Luis S.R. filed a petition in federal court asking to be released from immigration detention by challenging the legality of his confinement — a legal tool called a writ of habeas corpus.
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on March 26, 2026, recommending that the petition be denied. Luis S.R. did not file any objections to that recommendation within the allowed time, which means the court reviewed it only for obvious errors rather than conducting a full independent review.
On April 6, 2026, Judge Jerry W. Blackwell accepted the Magistrate Judge's Report and Recommendation and denied Luis S.R.'s petition for release. No reasons beyond the acceptance of the recommendation are stated in this order; the underlying reasoning is contained in the Magistrate Judge's Report and Recommendation, which is not reproduced here.
The detailed version
- S.R. v. Immigration and Customs Enforcement · No. 0:26-cv-01482
- Jerry W. Blackwell
- Apr. 6, 2026
Background
Petitioner Luis S.R. — identified in the case caption only by first name and last initial, consistent with court anonymization practice — filed an Amended Petition for a Writ of Habeas Corpus (Doc. No. 12) challenging his detention. The respondents are Immigration and Customs Enforcement (ICE), the Sheriff of Crow Wing County Minnesota in his official capacity, the Acting Field Office Director of ICE's Saint Paul Enforcement and Removal Operations office in his official capacity, the Acting Director of ICE in his official capacity, the U.S. Secretary of Homeland Security in his official capacity, and the Attorney General of the United States in her official capacity.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on March 26, 2026 (Doc. No. 22), recommending denial of the petition. The opinion does not reproduce the substance or reasoning of the R&R; the R&R itself would contain the legal analysis.
Standard of Review Applied
Because no objections were filed to the R&R within the permitted time, Judge Blackwell applied the "clear error" standard of review — a deferential standard under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (citing Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996)). Under this standard, the district court will accept the magistrate judge's recommendation unless it contains an obvious mistake. Judge Blackwell found no clear error.
Ruling
Judge Blackwell accepted the March 26, 2026 R&R and denied Luis S.R.'s Amended Petition for a Writ of Habeas Corpus. The court ordered that judgment be entered accordingly. The order does not state the specific grounds for denial beyond accepting the R&R, and the opinion text provided does not include the R&R's reasoning.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.