Case: Soumare v. Rife
2:26-cv-04332 | U.S. District Court for the Eastern District of Pennsylvania
Filed Date: June 24, 2026
Case Ongoing
Clearinghouse coding complete
Case Summary
This is a case challenging the rescission of the Philadelphia Immigration and Customs Enforcement (ICE) Field Office's "Changed Circumstances Policy," which has led to the re-detention of individuals amid a nationwide push to increase arrests and detentions.
On June 24, 2026, three named plaintiffs filed a class action complaint in the U.S. District Court for the Eastern District of Pennsylvania against the Philadelphia ICE Field Office and the U.S. Department of Homeland Security (DHS). The plaintiffs, represented by the ACLU, public interest law firms, and the Robert & Ethel Kennedy Human Rights Center, challenged the 2025 Philadelphia ICE Field Office decision to rescind its longstanding Changed Circumstances Policy. The policy previously required a material change in circumstances to justify re-arresting or re-detaining individuals who were previously released from DHS custody, under which noncitizens who posed no danger to the community and no flight risk could remain out of custody during removal proceedings. The plaintiffs asserted three causes of action under the Administrative Procedure Act (APA): that the rescission was arbitrary and capricious, that it violated Fourth Amendment protections, and that it contravened the Immigration and Nationality Act (INA). The proposed class included all noncitizens subject to re-arrest or re-detention by the Philadelphia ICE Field Office who were in removal proceedings and not subject to mandatory detention, with a subclass of those initially released on bond, released on conditional parole, or bound by a legal promise to appear in court. The plaintiffs sought class certification, appointment of class counsel, vacatur of the rescission, a declaration that the policy change was unlawful, and an award of attorneys’ fees and costs. This case was assigned to District Judge Catherine C. Henry.
That same day, the plaintiffs moved to stay the rescission and to certify a class.
On July 30, 2026, the court ordered the government to file its motion to dismiss by August 12, 2026, and the plaintiffs to respond by September 2, 2026. The case remains ongoing.
Summary Authors
Madeline Dollard (8/4/2026)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/73524424/parties/soumare-v-rife/
Armstrong, Keith (Pennsylvania)
GROGAN, JOHN J. (Pennsylvania)
NAGDEMAN, DAVID A. (Pennsylvania)
Pena-Parr, Victoria (Pennsylvania)
STINE, VANESSA L. (Pennsylvania)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/73524424/soumare-v-rife/
Last updated Aug. 4, 2026, 1:01 p.m.
Case Details
State / Territory:
Case Type(s):
Special Collection(s):
Trump Administration 2.0: Litigation and Investigations Involving the Government
Trump Administration 2.0: Reversing Course on Existing Litigation
Key Dates
Filing Date: June 24, 2026
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Noncitizens subject to re-arrest or re-detention by the ICE's Philadelphia Field Office who were now in removal proceedings and not subject to mandatory detention, with a subclass of those initially released on bond, released on conditional parole, or bound by a legal promise to appear in court
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Pending
Defendants
Federal
Department of Homeland Security (DHS)
Regional
ICE Philadelphia Field Office
Defendant Type(s):
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Immigration and Nationality Act (INA), 8 U.S.C. §§ 1101 et seq.
Constitutional Clause(s):
Unreasonable search and seizure
Other Dockets:
Eastern District of Pennsylvania 2:26-cv-04332
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Sought:
Relief Granted:
Source of Relief:
Issues
Immigration/Border:
Undocumented immigrants - rights and duties
Case Summary of Soumare v. Rife, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/48316/ (last updated 8/4/2026).