FILED
April 09, 2026
CLERK, U.S. DISTRICT COURT
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS
WESTERN DISTRICT OF TEXAS BY: ________________________________
CSanchez
EL PASO DIVISION DEPUTY
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HON. DAVID C. GUADERRAMA § ALL IMMIGRATION HABEAS CASES
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STANDING ORDER TO PROVIDE STATUS UPDATES
IN IMMIGRATION HABEAS CASES
In recent months, individuals in immigration detention have filed hundreds of petitions
for writs of habeas corpus in the Western District of Texas. 1 While the Court considers the
merits of each petition, intervening developments in the petitioner’s removal proceedings can
alter the analytical framework of the case, or even moot the petition entirely. 2 To rule
intelligently and efficiently on each petition, the Court relies on the parties to provide notice
when any such development occurs.
1
See, e.g., Huanaga-Luna v. Bondi, No. 3:26-CV-00462-DCG, 2026 WL 822444, at *1 (W.D.
Tex. Mar. 19, 2026) (“Since June 2025, the undersigned Judge has received roughly 105 habeas corpus
petitions from immigration detainees.”).
See also, e.g., Longoria Mendoza v. Noem, No. 5:26-CV-0728-JKP, 2026 WL 809441, at *2
(W.D. Tex. Feb. 26, 2026) (“The Court could not agree more that the federal courts lack staff, time, and
resources to handle the flood of habeas cases resulting from the current emphasis on immigration
detention and removal.”).
2
See, e.g., Berrezueta v. Decker, No. 1:20-CV-10688, 2021 WL 601649, at *1 (S.D.N.Y. Jan. 11,
2021) (noting that “[r]elease from custody generally renders a habeas petition moot”).
See also, e.g., Zamudio Sanchez v. Noem, No. 3:25-CV-00403-DCG, 2026 WL 596133, at *16
(W.D. Tex. Mar. 2, 2026) (stating that “the Court has based its analysis on the assumption that [a removal
order] does not exist,” but “[i]f that assumption is incorrect, a different analytical framework may apply”
(citing Zadvydas v. Davis, 533 U.S. 678, 701 (2001))).
The Court therefore ORDERS that ANY PARTY to an immigration habeas case
SHALL inform the Court if:
(1) the Government transfers the petitioner to a new detention center;
(2) the Government grants the petitioner a custody redetermination hearing;
(3) the Government issues an order of removal against the petitioner;
(4) the petitioner’s order of removal becomes administratively final; 3
(5) the Government removes the petitioner to another country; or
(6) the Government otherwise releases the petitioner from custody.
That party SHALL provide such notice AS SOON AS POSSIBLE.
While the petitioner SHALL update the Court on any critical developments that occur
after the petition is filed, each party SHALL share this responsibility if and when the Court
orders the respondent(s) to show cause.
If the opposing party disagrees with the filing party’s characterization of the facts, that
party SHALL inform the Court within three days. 4
3
See 8 C.F.R. § 1241.1 (explaining how “[a]n order of removal made by the immigration judge at
the conclusion of proceedings under section 240 of the Act shall become final”).
4
See generally FED. R. CIV. P. 6(a)(1)(C) (“When the period is stated in days or a longer unit of
time . . . include the last day of the period, but if the last day is a Saturday, Sunday, or legal holiday, the
period continues to run until the end of the next day that is not a Saturday, Sunday, or legal holiday.”).
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Finally, the Clerk of Court SHALL DOCKET this Standing Order in all PENDING and
FUTURE civil cases labeled with the “Nature of Suit” code “463 Habeas Corpus – Alien
Detainee” and assigned to the undersigned Judge.
So ORDERED and SIGNED this 9th day of April 2026.
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DAVID C. GUADERRAMA
SENIOR U.S. DISTRICT JUDGE
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