Mendoza-Camacho v. Easterwood

Background

Petitioner Indriany S.M.C. arrived in the United States in December 2022 as an unaccompanied minor with an infant child. Immigration officials placed her in a humanitarian shelter and later released her to a legal guardian in Minnesota, finding she was neither dangerous nor a flight risk. On January 14, 2026, Respondents arrested her at gunpoint from inside her home while pursuing another adult at the same residence, then held her in Minnesota for four days before flying her to a detention facility in Texas.

The court previously granted Petitioner habeas corpus relief (a court order challenging the lawfulness of her detention) in a January 27, 2026 Order, directing her release in Minnesota without conditions. When Respondents released her subject to an Order of Release on Recognizance (OREC) — a document imposing conditions contrary to the court's order — Petitioner moved to strike the OREC. The court ordered Respondents to show cause why sanctions should not be imposed; Respondents rescinded the OREC and sanctions were not imposed.

Having prevailed, Petitioner moved for attorneys' fees and costs under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412, requesting $38,038.17 in fees for 155.5 hours, $534.42 in costs, and an additional $672.00 for preparing a reply to the EAJA petition. Respondents opposed the motion, seeking either full denial or an 80% reduction.

Legal Standard

Under the EAJA, a prevailing party is entitled to fees unless the government shows its position was "substantially justified" — meaning justified to a degree that could satisfy a reasonable person — or that special circumstances make an award unjust. 28 U.S.C. § 2412(d)(1)(A). The government's "position" encompasses both its litigation arguments and the underlying agency conduct that led to the lawsuit. 28 U.S.C. § 2412(d)(2)(D). Substantial justification requires both a reasonable basis in law and a reasonable basis in fact, and the burden rests on the government.

Analysis

Basis in Law

Respondents argued their position was substantially justified because the question of whether 8 U.S.C. § 1225 authorized Petitioner's detention was unsettled in the Eighth Circuit, and some district courts had agreed with them. The court acknowledged that after Respondents filed their EAJA response, the Eighth Circuit in Avila v. Bondi, 170 F.4th 1128 (8th Cir. 2026), agreed that § 1225(b)(2) imposes mandatory detention for "applicants for admission." The court noted, however, that even a losing legal position can be substantially justified, and that Avila did not address how § 1225 would apply to an unaccompanied minor resettled through a government program, nor did it examine the timing, location, or manner of the particular detention at issue. The court therefore accepted, for purposes of analysis, that Respondents' statutory interpretation had a reasonable basis in law — but found that this addressed only the legal component of the EAJA inquiry.

Basis in Fact

The court found the government had not met its burden on the factual component. Respondents offered no explanation for the underlying conduct: why Petitioner was selected for detention, why she was arrested at gunpoint inside her home, why she was flown to Texas, or why she was subjected to § 1225(b)(2) mandatory detention even though officials had previously released her into the country. Because the government bears the burden of justifying both the legal and factual dimensions of its position, and because it failed to address the factual basis at all, the court held that an EAJA award follows as a matter of law. The court also found no special circumstances making an award unjust.

Reasonableness of Fees

The EAJA sets a presumptive rate of $125 per hour, adjustable for cost-of-living increases. The court accepted Petitioner's requested base rate of $258.46 per hour for attorneys as a reasonable cost-of-living adjustment consistent with practice in the Eighth Circuit, and $125.00 per hour for support staff.

The court identified several problems with the billing records:

- Overstaffing: The case involved 10 attorneys from two firms, with one firm drafting the habeas petition and another assisting on the reply, without any explanation for the staffing structure or each attorney's distinct contribution. - Overlapping entries: Multiple attorneys billed for the same general tasks — e.g., one firm spent approximately 15 hours drafting the reply while the other spent roughly twice that on the same project — without distinguishing their individual contributions. - Block billing: Many entries grouped multiple activities together with no way to allocate time among them. - Unrelated work: Some entries related to Petitioner's separate habeas case filed in Texas (in which she did not prevail), to a roommate's case, to calls with reporters, or to other matters not clearly connected to this litigation. - Costs: The costs list included filing fees from the Texas case, and research charges did not specify the case or issue involved.

The court rejected Respondents' proposed 80% cut, finding it too severe. Respondents wrongly faulted counsel for not using a "template" petition and for researching issues beyond the statutory interpretation question; the court noted that habeas petitioners may raise alternative legal grounds in good faith, and that some work — including the Texas filing — resulted directly from Respondents' decision to fly Petitioner to Texas.

Applying its discretion under the EAJA and guided by Hensley v. Eckerhart, 461 U.S. 424 (1983), and Fox v. Vice, 563 U.S. 826, the court reduced the total fee request by 50% as a rough-justice measure that accounts for overstaffing and billing deficiencies while recognizing that a portion of each attorney's work was reasonably necessary.

Ruling

The court granted the fee motion in part and awarded Petitioner $19,622.30 (50% of $39,244.59) in reasonable costs and fees under the EAJA, 28 U.S.C. § 2412. The court also granted Petitioner's motion for leave to file a reply in support of the fee petition.