Case: Diaz v. Hott

1:17-cv-01405 | U.S. District Court for the Eastern District of Virginia

Filed Date: Dec. 7, 2017

Closed Date: June 29, 2021

Clearinghouse coding complete

Case Summary

This class action relates to an immigration detainee's access to bond hearings under the Immigration and Nationality Act (INA)(8 U.S.C. Ch. 12) when that person has been placed in withholding-only proceedings, which happen when an Immigration Judge (IJ) or asylum officer determines that the petitioner has a reasonable fear of persecution/torture if they are deported.Petitioners were all individually removed from the United States following deportation orders. Each petitioner received death thre…

This class action relates to an immigration detainee's access to bond hearings under the Immigration and Nationality Act (INA)(8 U.S.C. Ch. 12) when that person has been placed in withholding-only proceedings, which happen when an Immigration Judge (IJ) or asylum officer determines that the petitioner has a reasonable fear of persecution/torture if they are deported.

Petitioners were all individually removed from the United States following deportation orders. Each petitioner received death threats upon returning to their native countries, prompting them to return illegally to the US. Upon returning, the petitioners were detained by Immigration and Customs Enforcement (ICE) at Immigration Centers of America Farmfille in Virginia and were placed in withholding-only proceedings. The plaintiffs were represented by the Legal Aid Justice Center. The case was filed on December 7, 2017, in the US District Court for the Eastern District of Virginia, with Judge Leonie M. Brinkema presiding. Pursuant to 28 U.S.C. § 2241, the petitioners filed a habeas corpus petition seeking class certification and an order directing the Attorney General (then Jeff Sessions) and the Field Office Director for ICE to grant the plaintiffs bond hearings.

On January 12, 2018, the petitioners filed a motion for summary judgment. The government filed a cross motion for summary judgment on February 2. In a memorandum opinion from February 26, 2018, Judge Brinkema granted the petitioner’s motion for summary judgement on the grounds that the petitioners had been detained under § 1226(a) of the INA and that such detainees were entitled to bond hearings. Judge Brinkema also certified the class of petitioners and denied the government’s motion for summary judgment.

The government appealed the District Court summary judgment order to the U.S. Court of Appeals for the Fourth Circuit on April 19, 2018. The Fourth Circuit consolidated this appeal with an appeal from a very similar case, Romero v. Evans. On October 10, 2019, the Fourth Circuit affirmed the lower court rulings in both cases and ruled in favor of the petitioners. 940 F.3d 867.

The government petitioned the Supreme Court for a writ of certiorari on January 21, 2020. The Supreme Court granted certiorari on June 15, 2020 and designated the case Johnson v. Guzman Chavez. 141 S.Ct. 107.

On June 29, 2021, the Supreme Court reversed the Fourth Circuit Court of Appeals and ruled in favor of the government. First, the Court held that §1231 of the INA is the provision which applies to immigration detainees who sought to withhold removal proceedings based on fear of persecution if deported. Second, the Court held that §1231 of the INA doesn’t allow individualized bond hearings, and that therefore, the petitioners in this case were not entitled to such hearings. 2021 WL 2653264.

The Supreme Court’s ruling in favor of the government effectively ended the case.

Summary Authors

John Duffield (6/30/2021)

Related Cases

Romero v. Evans, Eastern District of Virginia (2017)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/6317442/parties/diaz-v-hott/


Judge(s)

Brinkema, Leonie M. (Virginia)

Nachmanoff, Michael Stefan (Virginia)

Attorneys(s) for Plaintiff

McFarland, Rachel Colleen (Virginia)

Reyes, James (Virginia)

Sandoval-Moshenberg, Simon (Virginia)

Stevens, Mark Alastair (Virginia)

Attorneys(s) for Defendant

McCotter, R. Trent (Virginia)

Judge(s)

Brinkema, Leonie M. (Virginia)

Nachmanoff, Michael Stefan (Virginia)

Attorneys(s) for Plaintiff

McFarland, Rachel Colleen (Virginia)

Reyes, James (Virginia)

Sandoval-Moshenberg, Simon (Virginia)

Stevens, Mark Alastair (Virginia)

Attorneys(s) for Defendant

McCotter, R. Trent (Virginia)

Documents in the Clearinghouse

Document

1:17-cv-01405

Docket [PACER]

Cabrera Diaz v. Hott

Feb. 14, 2020

Feb. 14, 2020

Docket
31

1:17-cv-01405

Memorandum Opinion

Cabrera Diaz v. Hott

Feb. 26, 2018

Feb. 26, 2018

Order/Opinion

18-6086

Order

U. S. Court of Appeals for the Fourth Circuit

Oct. 10, 2019

Oct. 10, 2019

Order/Opinion

19-897

Petition for a Writ of Certiorari

Albence v. Guzman Chavez

Supreme Court of the United States

Jan. 17, 2020

Jan. 17, 2020

Pleading / Motion / Brief

19-897

Brief in Opposition (Petition for a Writ of Certiorari)

Albence v. Guzman Chavez

Supreme Court of the United States

April 22, 2020

April 22, 2020

Pleading / Motion / Brief

19-897

Reply Brief for Petitioners (Petition for a Writ of Certiorari)

Albence v. Guzman Chavez

Supreme Court of the United States

May 14, 2020

May 14, 2020

Pleading / Motion / Brief

19-897

Order

Supreme Court of the United States

June 29, 2021

June 29, 2021

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/6317442/diaz-v-hott/

Last updated Sept. 3, 2022, 3:01 a.m.

ECF Number Description Date Link Date / Link
1

PETITION for Writ of Habeas Corpus ( Filing fee $ 5 receipt number 0422-5847609.), filed by Rogelio Amilcar Cabrera Diaz. (Attachments: # 1 Civil Cover Sheet)(acha, ) (Entered: 12/12/2017)

Dec. 7, 2017

Dec. 7, 2017

PACER
2

AMENDED Petition First Amended Petition for Habeas Corpus (Class Action Habeas Corpus Petition) against Russell Hott, Jefferson B. Sessions, III, filed by Rogelio Amilcar Cabrera Diaz.(Sandoval-Moshenberg, Simon) (Entered: 12/15/2017)

Dec. 15, 2017

Dec. 15, 2017

PACER
3

NOTICE of Appearance by Mark Alastair Stevens on behalf of Rogelio Amilcar Cabrera Diaz (Stevens, Mark) (Entered: 12/15/2017)

Dec. 15, 2017

Dec. 15, 2017

PACER
4

AMENDED Petition Second Amended Petition against Russell Hott, Jefferson B. Sessions, III, filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Attachments: # 1 Exhibit A: Written Consent of Respondents, Fed.R.Civ.P. 15(a)(2))(Sandoval-Moshenberg, Simon) (Entered: 01/05/2018)

Jan. 5, 2018

Jan. 5, 2018

PACER
5

Motion to appear Pro Hac Vice by Adam Hudes and Certification of Local Counsel Simon Sandoval-Moshenberg Filing fee $ 75, receipt number 0422-5887443. by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 01/09/2018)

Jan. 9, 2018

Jan. 9, 2018

PACER
6

Motion to appear Pro Hac Vice by Paul W. Hughes and Certification of Local Counsel Simon Sandoval-Moshenberg Filing fee $ 75, receipt number 0422-5887457. by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 01/09/2018)

Jan. 9, 2018

Jan. 9, 2018

PACER
7

NOTICE of Appearance by Rachel Colleen McFarland on behalf of Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco (McFarland, Rachel) (Entered: 01/09/2018)

Jan. 9, 2018

Jan. 9, 2018

PACER
8

AGREED ORDER- It is hereby ORDERED that the following schedule shall apply to this action: 1. All Respondents' answers are waived. 2. Petitioners shall file their Motion for Summary Judgment and Motion for Class on or before Friday, January 12, 2018. Signed by District Judge Leonie M. Brinkema on 1/10/2018. (acha, ) (Entered: 01/10/2018)

Jan. 10, 2018

Jan. 10, 2018

PACER
9

ORDER granting 5 Motion for Pro hac vice for Adam Hudes. Signed by District Judge Leonie M. Brinkema on 1/10/2018. (acha, ) (Entered: 01/10/2018)

Jan. 10, 2018

Jan. 10, 2018

PACER
10

ORDER granting 6 Motion for Pro hac vice for Paul W.Hughes. Signed by District Judge Leonie M. Brinkema on 1/10/2018. (acha, ) (Entered: 01/10/2018)

Jan. 10, 2018

Jan. 10, 2018

PACER

Alexandria Set Hearings: Summary Judgment Hearing set for 2/23/2018 at 10:00 AM in Alexandria Courtroom 700 before District Judge Leonie M. Brinkema. (acha, )

Jan. 10, 2018

Jan. 10, 2018

PACER
11

MOTION to Certify Class by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
12

Memorandum in Support re 11 MOTION to Certify Class filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Proposed Order)(Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
13

Notice of Hearing Date February 23, 2018, 10:00am re 11 MOTION to Certify Class, 12 Memorandum in Support, (Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
14

NOTICE of Appearance by R. Trent McCotter on behalf of Russell Hott, Jefferson B. Sessions, III (McCotter, R.) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
15

MOTION to Seal by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Attachments: # 1 Proposed Order)(Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
16

MOTION for Summary Judgment by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Attachments: # 1 Proposed Order)(Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
17

Memorandum in Support re 16 MOTION for Summary Judgment filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N)(Sandoval-Moshenberg, Simon) (Attachment 5 replaced on 1/17/2018) (acha, ). (Attachment 6 replaced on 1/17/2018) (acha, ). (Attachment 7 replaced on 1/17/2018) (acha, ). (Attachment 11 replaced on 1/17/2018) (acha, ). (Attachment 12 replaced on 1/17/2018) (acha, ). (Attachment 13 replaced on 1/17/2018) (acha, ). per LMB chambers Modified on 1/17/2018 (acha, ). (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER
18

Notice of Hearing Date Feb. 23, 2018 set for Feb. 23, 2018 re 17 Memorandum in Support, 16 MOTION for Summary Judgment, 15 MOTION to Seal (Sandoval-Moshenberg, Simon) (Entered: 01/12/2018)

Jan. 12, 2018

Jan. 12, 2018

PACER

Set Deadlines as to 11 MOTION to Certify Class, 16 MOTION for Summary Judgment, 15 MOTION to Seal . Motion Hearing set for 2/23/2018 at 10:00 AM in Alexandria Courtroom 700 before District Judge Leonie M. Brinkema. (clar, )

Jan. 16, 2018

Jan. 16, 2018

PACER
19

ORDER- It is hereby ORDERED that 15 Petitioner's Motion to Seal and Redact is GRANTED; and further it is hereby ORDERED that the Proposed Sealed Documents shall be maintained under seal by the Clerk, until otherwise directed. The COURT further FINDS that Petitioners have established good cause to redact their entire Alien Registration Numbers from all other exhibits filed in support of their Motion for Summary Judgment and ORDERS that the unredacted copies of these exhibits be maintained under seal by the Clerk, until otherwise directed. Signed by District Judge Leonie M. Brinkema on 1/16/2018. (See order for further details). (acha, ) (Entered: 01/16/2018)

Jan. 16, 2018

Jan. 16, 2018

PACER
20

Memorandum in Opposition re 16 MOTION for Summary Judgment filed by Russell Hott, Jefferson B. Sessions, III. (Attachments: # 1 Exhibit Davila Declaration, # 2 Exhibit Lee Declaration, # 3 Exhibit Davila Declaration II)(McCotter, R.) (Entered: 02/02/2018)

Feb. 2, 2018

Feb. 2, 2018

PACER
21

Cross MOTION for Summary Judgment by Russell Hott, Jefferson B. Sessions, III. (McCotter, R.) (Entered: 02/02/2018)

Feb. 2, 2018

Feb. 2, 2018

PACER
22

Memorandum in Support re 21 Cross MOTION for Summary Judgment filed by Russell Hott, Jefferson B. Sessions, III. (Attachments: # 1 Exhibit Davila Declaration, # 2 Exhibit Lee Declaration, # 3 Exhibit Davila Declaration II)(McCotter, R.) (Entered: 02/02/2018)

Feb. 2, 2018

Feb. 2, 2018

PACER
23

Notice of Hearing Date set for February 23, 2018 re 21 Cross MOTION for Summary Judgment (McCotter, R.) (Entered: 02/02/2018)

Feb. 2, 2018

Feb. 2, 2018

PACER
24

Memorandum in Opposition re 11 MOTION to Certify Class filed by Russell Hott, Jefferson B. Sessions, III. (McCotter, R.) (Entered: 02/02/2018)

Feb. 2, 2018

Feb. 2, 2018

PACER

Set Deadlines as to 21 Cross MOTION for Summary Judgment . Motion Hearing set for 2/23/2018 at 10:00 AM in Alexandria Courtroom 700 before District Judge Leonie M. Brinkema. (clar, )

Feb. 5, 2018

Feb. 5, 2018

PACER
25

REPLY to Response to Motion re 16 MOTION for Summary Judgment filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 02/09/2018)

Feb. 9, 2018

Feb. 9, 2018

PACER
26

RESPONSE in Opposition re 21 Cross MOTION for Summary Judgment filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 02/09/2018)

Feb. 9, 2018

Feb. 9, 2018

PACER
27

REPLY to Response to Motion re 11 MOTION to Certify Class filed by Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, Rodolfo Eduardo Rivera Flamenco. (Sandoval-Moshenberg, Simon) (Entered: 02/09/2018)

Feb. 9, 2018

Feb. 9, 2018

PACER
28

NOTICE of Appearance by James Reyes on behalf of Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera (Reyes, James) (Entered: 02/11/2018)

Feb. 11, 2018

Feb. 11, 2018

PACER
29

REPLY to Response to Motion re 21 Cross MOTION for Summary Judgment filed by Russell Hott, Jefferson B. Sessions, III. (McCotter, R.) (Entered: 02/16/2018)

Feb. 16, 2018

Feb. 16, 2018

PACER
30

Minute Entry for proceedings held before District Judge Leonie M. Brinkema:Motion Hearing held on 2/23/2018. Appearances of counsel. Petitioners 11 MOTION to Certify Class and 16 MOTION for Summary Judgment are argued and TAKEN UNDER ADVISEMENT. (memorandum opinion to follow) (Court Reporter A. Thomson.)(yguy) (Entered: 02/26/2018)

Feb. 23, 2018

Feb. 23, 2018

PACER
31

MEMORANDUM OPINION: For the reasons stated above, petitioners' Motion to Certify Class [Dkt. No. 11 ] and Motion for Summary Judgment [Dkt. No. 16] will be granted and respondents' Motion for Summary Judgment [Dkt. No. 21] will be denied by an appropriate Order to be issued with this Memorandum Opinion. Signed by District Judge Leonie M. Brinkema on 2/26/18. (yguy) (Entered: 02/26/2018)

Feb. 26, 2018

Feb. 26, 2018

RECAP
32

ORDER: For the reasons stated in open court and in the accompanying Memorandum Opinion, petitioners' Motion to Certify Class [Dkt. No. 11] and Motion for Summary Judgment [Dkt. No.16] are GRANTED, respondents' Motion for Summary Judgment [Dkt. No. 21] is DENIED, and it is hereby ORDERED that this civil action be and is CERTIFIED AS A CLASS ACTION pursuant to Federal Rules of Civil Procedure 23(a) and23(b)(2), with the class defined as all individuals who (1) are in withholding-only proceedings, having established a reasonable fear of persecution or torture, and such proceedings are not administratively final, or if final, a stay of removal has been granted by a United States Court of Appeals; and(2)as of December 7,2017 or at anytimethereafter are detained within the Commonwealth of Virginia under the authority of the United States Immigration and Customs Enforcement Agency; and it is further ORDERED that petitioners Rogelio Amilcar Cabrera Diaz, Jennry Francisco Moran Barrera, and Rodolfo Eduardo Rivera Flamenco be and are DESIGNATED AS CLASS REPRESENTATIVES of the certified class; and it is furtherORDERED that the class claim is that respondents have erroneously determined that class members are detained pursuant to 8 U.S.C. ยง 1231, rather than 8U.S.C. ยง 1226, and, on that basis, have illegally refused to provide class members who have not been designated as criminal aliens pursuant to 8 U.S.C. ยง 1226(c) with bond hearings, and as for class members designated as criminal aliens, a hearing under In re Joseph, 22 I. &N. Dec. 799 (BIA 1999), to challenge their classification as criminal aliens subject to mandatory detention; and it is further ORDERED that Legal Aid Justice Center; Mayer Brown LLP; Murray Osorio PLLC; and the Law Offices of James Reyes PLLC be and are APPOINTED AS CLASS COUNSEL; and it is further ORDERED that judgment be and is entered in favor of petitioners; and it is further ORDERED that, within fifteen (15) days of the dale of entry of this Order, respondents identify all class members to class counsel and provide a copy of this Order to all class members as well as to any attorney who has noticed an appearance on behalf of any class member in any pending immigration proceeding; and it is further ORDERED that respondents provide each class member an individualized bond hearing before an immigration judge or a Joseph hearing before an immigration judge within thirty (30) days of the date of entry of this Order. Signed by District Judge Leonie M. Brinkema on 2/26/18. (yguy) (Entered: 02/26/2018)

Feb. 26, 2018

Feb. 26, 2018

PACER
33

CLERK'S JUDGMENT: JUDGMENT is hereby entered in favor of the petitioners, Rogelio Amilcar Cabrera Diaz, et al on Behalf of Themselves and All Other Similarly Situated. (yguy) (Entered: 02/26/2018)

Feb. 26, 2018

Feb. 26, 2018

PACER
34

PROTECTIVE ORDER. Signed by District Judge Leonie M. Brinkema on 3/12/2018. (rban, ) (Entered: 03/12/2018)

March 12, 2018

March 12, 2018

PACER
35

Joint MOTION for Extension of Deadline to Provide Hearings by Russell Hott, Jefferson B. Sessions, III. (McCotter, R.) (Entered: 03/28/2018)

March 28, 2018

March 28, 2018

PACER
36

Waiver of re 35 Joint MOTION for Extension of Deadline to Provide Hearings ORAL ARGUMENT by Russell Hott, Jefferson B. Sessions, III (McCotter, R.) (Entered: 03/28/2018)

March 28, 2018

March 28, 2018

PACER
37

ORDER- It is hereby ORDERED that the deadline for defendants to provide each class member either an individualized bond hearing or a Joseph hearing before an immigration judge pursuant to this 32 Court's Order of February 26, 2018 be and is EXTENDED until April 6, 2018. Signed by District Judge Leonie M. Brinkema on 3/28/2018.(See order for further details.) (acha, ) (Entered: 03/29/2018)

March 28, 2018

March 28, 2018

PACER
38

NOTICE OF APPEAL as to 31 Memorandum Opinion, 32 Order,,,,,,,,,, 33 Clerk's Judgment by Russell Hott, Jefferson B. Sessions, III. (McCotter, R.) (Entered: 04/19/2018)

April 19, 2018

April 19, 2018

PACER
39

Transmission of Notice of Appeal to US Court of Appeals re 38 Notice of Appeal (All case opening forms, plus the transcript guidelines, may be obtained from the Fourth Circuit's website at www.ca4.uscourts.gov) (dest, ) (Entered: 04/20/2018)

April 20, 2018

April 20, 2018

PACER
40

USCA Case Number 18-6419 4th Circuit, Case Manager C. Halupa for 38 Notice of Appeal filed by Russell Hott, Jefferson B. Sessions, III. (acha, ) (Entered: 04/24/2018)

April 23, 2018

April 23, 2018

PACER
41

USCA Mandate re 38 Notice of Appeal. The judgment of this court, entered October 10, 2019, takes effect today. (acha, ) (Entered: 02/14/2020)

Feb. 14, 2020

Feb. 14, 2020

PACER

Case Details

State / Territory: Virginia

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Post-WalMart decisions on class certification

Key Dates

Filing Date: Dec. 7, 2017

Closing Date: June 29, 2021

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Immigration detainees placed in withholding-only proceedings--meaning the person is in custody after either an Immigration Judge (IJ) or asylum officer determined the petitioner has a reasonable fear of persecution/torture if they are deported.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Legal Services/Legal Aid

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

U.S. Immigration and Customs Enforcement (DC), Federal

Defendant Type(s):

Jurisdiction-wide

Law-enforcement

Case Details

Causes of Action:

Immigration and Nationality Act (INA), 8 U.S.C. §§ 1101 et seq.

Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Due Process

Due Process: Procedural Due Process

Special Case Type(s):

Habeas

Availably Documents:

Trial Court Docket

Non-settlement Outcome

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Content of Injunction:

Preliminary relief granted

Issues

General:

Access to lawyers or judicial system

Fines/Fees/Bail/Bond

Habeas Corpus

Over/Unlawful Detention

Placement in detention facilities

Type of Facility:

Government-run

Immigration/Border:

Asylum - procedure

Detention - criteria

Detention - procedures