Case: Fulton v. Mayorkas
1:25-cv-00063 | U.S. District Court for the Western District of New York
Filed Date: Jan. 19, 2025
Case Ongoing
Clearinghouse coding complete
Case Summary
On January 19, 2025, a Jamaican citizen suffering from End Stage Renal Disease, detained at Buffalo Federal Detention and subject to removal for a criminal conviction, sought habeas relief in U.S. District Court for the Western District of New York from removal because it would deprive him of adequate medical treatment absent planning and scheduling of treatments. Petitioner was detained by the United States Immigration and Customs Enforcement (ICE) as of August 25, 2023 for removal proceedings following his conviction for attempted burglary in September 2022. The Immigration Judge denied his application for relief from removal and the Board of Immigration Appeals affirmed such denial on May 2, 2024, making him subject to a final order of removal as of that date. ICE scheduled Petitioner for deportation to Jamaica on January 30, 2025.
In his petition, Petitioner argued that removal without medical planning would violate (1) the Administrative Procedure Act, because ongoing detention without adequate medical care constitutes arbitrary agency action because it violates national detention standards, (2) the state-created danger doctrine under the Fifth Amendment’s substantive due process guarantee because effectuating removal without scheduled treatments “is egregious and shocks the conscience,” and (3) the Fifth Amendment’s procedural due process guarantee because effectuating removal without ensuring treatment creates “a substantial risk of an erroneous deprivation of [his] core interest in life and liberty.” He sought (1) an order to cease removal proceedings unless the government can demonstrate that post-removal medical appointments have been scheduled for him and (2) an order that the government cease actions toward effectuating his removal until the Court has adjudicated this petition.
The District Court granted the government’s motion to dismiss, denying jurisdiction to review his claim under 8 U.S.C. § 1252(g); federal courts do not have jurisdiction to hear habeas corpus claims that challenge the Attorney General’s decision to execute removal orders.
On January 29, 2025, the U.S. Court of Appeals for the Second Circuit granted a motion for stay of removal pending appeal. The case is pending.
Summary Authors
Ashton Smith (9/22/2026)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69572920/parties/fulton-v-mayorkas/
Sinatra, John Leonard (New York)
Moar, Daniel Barrie (New York)
Decker, Sarah Emma (New York)
Gillman, Sarah Telo (New York)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/69572920/fulton-v-mayorkas/
Last updated Sept. 22, 2026, 12:37 p.m.
Docket for: Fulton v. Mayorkas
Case Details
State / Territory:
Case Type(s):
Healthcare Access and Reproductive Issues
Key Dates
Filing Date: Jan. 19, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Immigration detainee challenging ICE detention and imminent removal through habeas and injunctive relief.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Defendants
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Declaratory Judgment Act, 28 U.S.C. § 2201
Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255
Immigration and Nationality Act (INA), 8 U.S.C. §§ 1101 et seq.
Constitutional Clause(s):
Due Process: Procedural Due Process
Due Process: Substantive Due Process
Other Dockets:
Western District of New York 1:25-cv-00063
Special Case Type(s):
Outcome
Prevailing Party: Defendant
Relief Sought:
Issues
Immigration/Border:
Jails, Prisons, Detention Centers, and Other Institutions:
Medical/Mental Health Care:
Case Summary of Fulton v. Mayorkas, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/46514/ (last updated 9/22/2026).