The Fifth Circuit Court of Appeals is reviewing a habeas corpus petition filed by Muhammad Imran, a Pakistani national currently detained by the Department of Homeland Security, in a case that raises questions about the limits of immigration detention under federal law.
Imran filed his "Complaint and Petition for Writ of Habeas Corpus" under 28 U.S.C. § 2241 in the U.S. District Court for the Western District of Louisiana, challenging his continued detention by DHS. The case, designated as No. 25-30370, was filed against multiple federal officials including DHS Secretary Kristi Noem, along with Mellissa Harper, Todd Lyons, and Eleazar Garcia.
According to court documents filed Jan. 13, 2026, Imran's petition asserts multiple legal claims challenging the basis for his detention. The case invokes the Administrative Procedures Act, constitutional protections under the Eighth Amendment, the Suspension Clause, and the Due Process Clause of the Fifth Amendment, as well as provisions of the Immigration and Nationality Act.
Central to Imran's legal challenge is the Supreme Court's decision in Zadvydas v. Davis (2001), which established important limitations on the government's authority to detain immigrants indefinitely. The Zadvydas ruling held that the government cannot detain immigrants indefinitely when there is no significant likelihood of removal in the reasonably foreseeable future, typically interpreted as a six-month period.
The case comes before a three-judge panel consisting of Circuit Judges Haynes, Duncan, and Ramirez. The court issued a per curiam opinion, indicating the decision was made collectively by the panel rather than authored by a single judge. Court records show the opinion is not designated for publication under Fifth Circuit Rule 47.5.
Immigration detention cases have become increasingly complex as courts balance national security concerns with constitutional protections for individuals in federal custody. The involvement of high-ranking DHS officials, including Secretary Noem, suggests the case may have broader implications for immigration enforcement policies and detention practices.
The Western District of Louisiana, where the case originated under USDC No. 1:25-CV-841, has seen numerous immigration-related cases as the region handles significant immigration enforcement activities. The district court's initial ruling prompted Imran's appeal to the Fifth Circuit, though the specific outcome of the lower court proceedings is not detailed in the available court documents.
Imran's petition seeks release from federal custody and appears to request a halt to certain detention-related actions, though the complete scope of his requested relief is not fully outlined in the available court filings. The case involves both statutory interpretation of immigration law and constitutional questions about the limits of detention authority.
The Fifth Circuit's handling of this case could provide important guidance for similar detention challenges throughout the circuit, which covers Texas, Louisiana, and Mississippi. Immigration attorneys often closely monitor Fifth Circuit decisions given the court's jurisdiction over states with significant immigration enforcement activities.
The legal framework surrounding immigration detention has evolved significantly since the Zadvydas decision more than two decades ago. Courts continue to grapple with questions about when detention becomes unconstitutionally prolonged and what standards apply to different categories of detainees.
Constitutional challenges to immigration detention often invoke multiple legal theories, as seen in Imran's case. The combination of Administrative Procedures Act claims with constitutional due process and Eighth Amendment arguments reflects the complex legal landscape surrounding federal detention authority.
The case also highlights ongoing debates about the scope of executive authority in immigration enforcement and the role of federal courts in reviewing detention decisions. The naming of the DHS Secretary as a respondent indicates the case may challenge policies or practices at the highest levels of the department.
As the Fifth Circuit considers Imran's appeal, the outcome could affect how courts in the circuit evaluate similar detention challenges. The court's analysis of the Zadvydas framework and its application to Imran's specific circumstances may provide precedential value for future cases involving prolonged immigration detention.
The timing of the case, with filings in early 2026, places it within the current administration's immigration enforcement priorities under Secretary Noem's leadership at DHS. The resolution of Imran's detention challenge will likely be closely watched by immigration attorneys and advocacy groups monitoring detention practices and policies.
While the court's per curiam opinion indicates a decision has been reached, the specific ruling and its reasoning remain to be fully disclosed through additional court filings or published opinions that may follow this initial procedural document.
