Easterwood v. Easterwood
- Katherine Menendez
- 0:26-cv-03588
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Samson C.C. v. Easterwood, Judge Menendez temporarily blocked the government from removing the petitioner from the United States while the court receives full briefing on his due-process claims.
People in immigration proceedings in the District of Minnesota who face potential removal to a third country and who claim they have not received constitutionally required due-process protections before removal.
What happened
In Samson C.C. v. David Easterwood, et al., No. 26-cv-3588, a person identified only as Samson C.C. filed an emergency motion asking the federal court in Minnesota to stop the government from transferring him out of Minnesota and then out of the United States before he receives the due-process protections he says he is owed under the Fifth Amendment and federal regulations.
The court found that, at least at this early stage, it likely has the legal authority to hear the case under binding appeals-court precedent. It also found that the balance of interests strongly favors the petitioner: if no order issues and he is removed to a third country, he could be beyond the court's reach permanently, while a brief delay appears unlikely to cause serious harm to the government.
Judge Katherine M. Menendez granted the emergency motion in part, temporarily ordering the government not to remove Samson C.C. from the United States while the parties prepare full briefing on his underlying motion for a temporary restraining order. The court also directed the parties to quickly agree on an expedited briefing schedule.
The detailed version
- Easterwood v. Easterwood · No. 0:26-cv-03588
- Katherine Menendez
- Aug. 11, 2026
Background
Petitioner Samson C.C. (identified only by that name in the court's caption, which uses initials in place of a full surname) filed an emergency motion for a temporary restraining order (TRO) — a short-term court order blocking a specific action until the court can hold a fuller hearing. He sought to prevent Respondents from transferring him out of the District of Minnesota and from removing him to a third country. His core legal claim is that such a transfer and removal, before he receives a meaningful opportunity to be heard, would violate the Fifth Amendment's Due Process Clause and applicable federal regulations.
The Court's Preliminary Analysis
The court noted it has previously addressed similar issues in comparable cases. Before entering a TRO, courts in the Eighth Circuit (the federal appeals court with jurisdiction over Minnesota) apply a four-factor framework from Dataphase Systems, Inc. v. C L Systems, Inc., 640 F.2d 109 (8th Cir. 1981), which weighs: (1) the likelihood of success on the merits, (2) the threat of irreparable harm to the moving party if relief is denied, (3) the balance between that harm and the harm a TRO would cause the opposing party, and (4) the public interest.
The court acknowledged that significant legal questions remain open — including whether it has jurisdiction, whether a petition for a writ of habeas corpus (a legal vehicle used to challenge unlawful detention or removal) is the proper procedural mechanism for this relief, and whether the petitioner will ultimately prevail on the merits. Nonetheless, the court noted that binding Eighth Circuit precedent, specifically Jama v. I.N.S., 329 F.3d 630 (8th Cir. 2003), affirmed in relevant part by the Supreme Court, provides at least a preliminary basis for jurisdiction.
On the balance of equities, the court found the scales tip heavily toward the petitioner: removal to a third country before the motion is fully briefed could place him permanently beyond the court's ability to grant any remedy, while a short delay pending briefing does not appear to risk irreparable harm to the government's interests.
Disposition
Judge Menendez granted the emergency motion in part and issued an initial TRO. The order temporarily enjoins (prohibits) Respondents from removing Samson C.C. from the United States while the parties brief the underlying TRO motion on a full record. The court also ordered the parties to meet and confer immediately to establish an expedited briefing schedule. The court did not grant the broader relief of preventing transfer within Minnesota — the order focuses on removal from the United States.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.