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Estrada Morales v. Bullock - Habeas Corpus Bond Hearing

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Summary

On April 22, 2026, the US District Court for the Western District of Tennessee ordered service and a stay of transfer in Kevin Francisco Estrada Morales's habeas petition under 28 U.S.C. § 2241, challenging his continued detention as an "arriving alien" without a bond hearing. The court directed that Estrada Morales serve copies of the petition and order on Respondent Christopher Bullock (ICE Field Office Director) and the US Attorney for the Western District of Tennessee within five days. The court also ordered that Respondent shall not transfer Estrada Morales out of the West Tennessee Detention Facility during the pendency of the Petition.

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GovPing monitors US District Court WDTN Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 3 changes logged to date.

What changed

The court issued an order requiring service of the habeas petition on Respondent and staying any transfer of Petitioner during pendency of the case. The order sets a five-day deadline for Petitioner to serve copies on Respondent and the US Attorney's Office, with Respondent required to respond within five days of full compliance. The court also reminded Petitioner's counsel to adhere to Local Rules regarding formatting (double-spacing, 12-point font). Any failure to comply may result in dismissal under Fed. R. Civ. P. 41(b).

Immigration detainees held as "arriving aliens" who are not receiving bond hearings may benefit from reviewing this petition's outcome, as it directly addresses challenges to prolonged detention without a bond hearing opportunity. Legal practitioners filing similar habeas petitions should note the court's directive on proper formatting and the requirement that the ICE District Director is the proper respondent.

Archived snapshot

Apr 24, 2026

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April 22, 2026 Get Citation Alerts Download PDF Add Note

Kevin Francisco Estrada Morales v. Christopher Bullock, New Orleans Field Office Director of Immigration and Customs Enforcement, Enforcement and Removal Operations

District Court, W.D. Tennessee

Trial Court Document

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION
)
KEVIN FRANCISCO ESTRADA )
MORALES, )
Petitioner, )
)
v. )
) No. 2:26-cv-02450-SHL-cgc
CHRISTOPHER BULLOCK1, New Orleans )
Field Office Director of Immigration and )
Customs Enforcement, Enforcement and )
Removal Operations, )
Respondent. )
)

ORDER REQUIRING SERVICE AND STAYING TRANSFER

On April 21, 2026, Petitioner Kevin Francisco Estrada Morales filed the Petition for a
Writ of Habeas Corpus under 28 U.S.C. § 2241.2 (ECF No. 1.) Estrada Morales challenges his
continued detention in the West Tennessee Detention Facility as an “arriving alien” without a
bond hearing. (ECF No. 1-3 at PageID 17.) He seeks immediate release from Respondent’s
custody. (Id.)
Upon review of the Petition, it is ORDERED as follows:
(1) Estrada Morales shall, within five days of this Order, serve one copy each of the

1 Christopher Bullock is the only appropriate Respondent for a habeas petition brought by
an alien in this district. See Rosciszewski v. Adducci, 983 F. Supp. 2d 910, 914 (E.D. Mich.
2013) (“[T]he ICE District Director is the proper respondent in a habeas petition brought by an
alien, since the District Director has power over such aliens.”). Accordingly, the U.S.
Department of Homeland Security and U.S. Immigration and Customs Enforcement are
dismissed from the case.

2 Estrada Morales’s counsel is DIRECTED to stop using Form AO 242, a pro se habeas
template, to file habeas petitions. Although the Local Rules make exceptions for pro se parties,
an attorney filing a petition in this district must adhere to the rules, including that filings must be
double-spaced with font no smaller than 12-point type. LR 7.1(b).
Petition (ECF Nos. 1, 1-1, 1-2, 1-3) and this Order (ECF No. 6) on each Respondent, and
ensure that copies are delivered to the United States Attorney for the Western District of
Tennessee at the following address:
Stuart Canale, Assistant United States Attorney
United States Attorney’s Office
167 North Main Street
Suite 800
Memphis, TN 38103
Additionally, Estrada Morales shall deliver a copy of this Order to the United States Attorney for
the Western District of Tennessee electronically at the following email address:
stuart.canale@usdoj.gov. Failure to fully comply with this requirement may justify dismissal
of the Petition. See Fed. R. Civ. P. 41(b) (“If the plaintiff fails to . . . comply with these rules or
a court order, a defendant may move to dismiss the action or any claim against it.”).
(2) Within five days after Estrada Morales fully complies with the above
requirement, Respondent shall respond to the Petition in writing.
(3) Estrada Morales may file a reply within two days after Respondent’s responsive
filing.
(4) Respondent shall not transfer Estrada Morales out of the West Tennessee
Detention Facility during the pendency of the Petition.
IT IS SO ORDERED, this 22nd day of April, 2026.
s/ Sheryl H. Lipman
SHERYL H. LIPMAN
CHIEF UNITED STATES DISTRICT JUDGE

Named provisions

28 U.S.C. § 2241 Fed. R. Civ. P. 41(b)

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Last updated

Classification

Agency
WDTN
Filed
April 22nd, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
No. 2:26-cv-02450
Docket
2:26-cv-02450

Who this affects

Applies to
Immigration detainees Government agencies
Industry sector
9211 Government & Public Administration
Activity scope
Habeas corpus proceedings Bond hearings Detention facility transfers
Geographic scope
US-TN US-TN

Taxonomy

Primary area
Immigration
Operational domain
Legal
Topics
Judicial Administration

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