PABLO ALEJANDRO ZAMORA MEJIA
v.
KRISTI NOEM ET AL.
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Zamora Mejia petitioned for habeas corpus relief challenging his immigration detention, claiming he possessed temporary protected status (TPS). The district court granted relief by issuing a temporary restraining order directing his release, but subsequently dismissed the petition as moot because he was no longer in custody and alleged no persisting collateral consequences.
The habeas petition is dismissed as moot. Because Zamora Mejia is no longer in custody and alleges no persisting collateral consequences from his imprisonment, the case no longer presents a live controversy and the Court cannot grant meaningful relief.
[1] A habeas petition presents a live case or controversy only when a petitioner is in custody.
[2] A habeas action may continue after a petitioner's release from custody if the petitioner demonstrates that a collateral consequence of their imprisonment persists.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“As a general rule, a habeas petition presents a live case or controversy only when a petitioner is in custody.”
Establishes the threshold requirement for habeas jurisdiction that the petitioner must be in custody.
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Join FLexlaw to unlock all legal intelligenceZamora Mejia was detained in immigration custody. He petitioned for habeas corpus relief asserting that he possessed temporary protected status (TPS) …
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Before the Court is Pablo Alejandro Zamora Mejia's Emergency Petition for Writ of Habeas Corpus Pursuant to 28 U.S.C. § 2241 and for Immediate Release (Doc. 1). The petition asserts Zamora Mejia's immigration detention was unlawful because he has temporary protected status (“TPS") through November 7, 2025. The Court agrees. Yesterday, the Court entered a temporary restraining order, directing the respondents to release Zamora Mejia from custody and enjoining them from detaining Zamora Mejia while he has TPS. (Doc. 16). The respondents complied, and Zamora Mejia is no longer in custody. (See Docs. 17 and 18).
“As a general rule, a habeas petition presents a live case or controversy only when a petitioner is in custody." Djadju v. Vega, 32 F. 4th 1102, 1106 (11th Cir. 2022) (quoting Salmeron-Salmeron v. Spivey, 926 F. 3d 1283, 1289 (11th
Cir. 2019)). A habeas action may continue after the petitioner's release from custody only if the petitioner establishes “that his case still presents a live ‘case or controversy' by demonstrating that a collateral consequence of his imprisonment persists after his release." Id. at 1107. “The fundamental question is whether events have occurred that deprive [the Court] of the ability to give the [petitioner] meaningful relief.” Id.
Zamora Mejia is no longer in custody, and his petition alleges no persisting collateral consequences. The Court cannot grant any additional meaningful relief. Accordingly, this action is dismissed as moot. The Clerk is directed to terminate any pending deadlines, enter judgment, and close this case.
DONE AND ORDERED in Fort Myers, Florida on November 5, 2025.
Sheri Polster Rappell SHERI POLSTER CHAPPELL UNITED STATES DISTRICT JUDGE
SA: FTMP-1
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Salmeron-Salmeron v. Warden Bill Spivey, 926 F.3d 1283 (11th Cir. 2019)
- Goga Djadju v. Vega, 32 F. 4th 1102 (11th Cir. 2022)