My C. v. Bondi

Background

My C. filed a petition under 28 U.S.C. § 2241 challenging her continued immigration detention. She argued that her detention was unconstitutional because it exceeded the presumptively reasonable six-month period discussed in Zadvydas v. Davis and because there was no significant likelihood of her removal in the reasonably foreseeable future.

My C. was removed from the United States to Vietnam on March 15, 2026, under a final removal order. Before her removal, immigration officials had obtained a Vietnamese travel document. The opinion states that she was no longer in custody or within the court’s jurisdiction after her removal.

Reasoning

The report explains that federal courts may decide only ongoing cases or controversies. A case becomes moot when changed circumstances mean the court can no longer provide effective relief. Because My C. had been removed, the court could no longer grant relief from the challenged detention.

The report considered exceptions to mootness, including continuing collateral injuries, issues capable of repetition yet evading review, a defendant’s voluntary cessation of conduct that could resume, and certified class actions. It concluded that none applied. The report also expressly stated that, because the petition was moot, it did not decide whether the revocation of My C.’s supervised release or the resulting immigration detention was lawful.

Recommendation and procedural status

Judge John F. Docherty recommended that My C.’s petition be denied as moot and that the matter be dismissed without prejudice for lack of jurisdiction. The document is a magistrate judge’s Report and Recommendation, not a final district court order or judgment. The notice states that it was not directly appealable and that objections could be filed within the specified period.