The U.S. Court of Appeals for the Third Circuit issued a precedential opinion on Feb. 2, 2026, in consolidated immigration detention cases that could significantly impact federal immigration enforcement practices across the circuit.
The consolidated cases, *Adolph Michelin v. Warden Moshannon Valley Correctional Center* and *Adewumi Abioye v. Warden Moshannon Valley Processing Center*, were originally filed in the U.S. District Court for the Western District of Pennsylvania in 2023. Both cases challenged the detention of immigration detainees at Moshannon Valley facilities operated under federal immigration enforcement authority.
The appeals court consolidated the matters under case numbers 24-2990 and 24-3198 before a three-judge panel consisting of Circuit Judges Restrepo, McKee, and Ambro. Oral arguments were held on Nov. 10, 2025, with the court issuing its written opinion approximately three months later.
Michelin's case names multiple federal defendants including the Warden of Moshannon Valley Correctional Center, the Director of the Philadelphia Field Office of Immigration and Customs Enforcement, the Director of U.S. Immigration and Customs Enforcement, the Secretary of the U.S. Department of Homeland Security, and the Attorney General of the United States.
Similarly, Abioye's case targets the Warden of Moshannon Valley Processing Center, the Acting Field Office Director of ICE and Removal Operations Philadelphia Field Office, the Secretary of the Department of Homeland Security, and the Attorney General.
The cases were initially heard by Magistrate Judges Patricia L. Dodge and Christopher B. Brown in the Western District of Pennsylvania. The original district court case numbers were 3:23-cv-00022 for Michelin and 3:23-cv-00251 for Abioye, indicating both lawsuits were filed in 2023.
Representing the federal government defendants, the U.S. Attorney's Office for the Western District of Pennsylvania and the Department of Justice's Office of Immigration Litigation deployed a team of attorneys. Laura S. Irwin from the Pittsburgh U.S. Attorney's Office joined Joseph A. McCarter and Sarah S. Wilson from the Justice Department's Immigration Litigation office in Washington, D.C. McCarter argued the case for the government.
The detainees were represented by a coalition of immigration attorneys from multiple organizations. Arnold & Porter Kaye Scholer provided representation through attorneys Casey Corcoran, Robert S. Jones, Andrew Tutt, and Kathleen Weng from their Washington, D.C. office. The Nationalities Service Center in Philadelphia contributed attorney Jonah B. Eaton to the defense team. Nicole L. Masiello and William Sharon, also from Arnold & Porter, rounded out the legal representation, with Sharon arguing on behalf of the petitioners.
The Third Circuit's designation of this opinion as "precedential" signals that the decision will serve as binding authority for future immigration detention cases within the circuit, which covers Pennsylvania, New Jersey, Delaware, and the U.S. Virgin Islands. Precedential opinions carry more weight than non-precedential decisions and must be followed by lower courts within the jurisdiction.
While the specific holdings and reasoning of the court's opinion were not detailed in the available case caption and procedural information, the involvement of multiple high-level federal defendants suggests the cases addressed fundamental questions about immigration detention authority and procedures at federal facilities.
The Moshannon Valley facilities have been the subject of various legal challenges related to immigration detention conditions and procedures. The consolidation of these two cases indicates the court recognized common legal issues that warranted joint consideration and resolution.
The extensive legal representation on both sides, including specialized immigration litigation attorneys from the Justice Department and prominent private firms, underscores the complexity and potential significance of the legal issues presented to the appeals court.
The timing of the decision, coming in early 2026, positions this precedential ruling to influence immigration detention practices and legal challenges throughout the new year. Immigration attorneys and federal officials will likely study the opinion closely to understand its implications for similar detention cases and enforcement procedures.
Given the precedential nature of the ruling and the high-profile defendants involved, including cabinet-level officials, this decision represents a notable development in immigration law within the Third Circuit's jurisdiction. The court's resolution of these consolidated challenges may provide guidance for future cases involving federal immigration detention facilities and enforcement procedures.
The cases highlight ongoing legal tensions surrounding immigration detention practices and the rights of individuals held in federal immigration facilities, issues that continue to generate significant litigation across federal courts nationwide.