Zolicoffer v. DOJ

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• collecting cases, finding that absent an order of removal “prisoners are not ‘in custody’ for purposes of 28 U.S.C. § 2241 simply because the INS has lodged a detainer against them.”
• “agree[ing] with the majority of circuit courts considering this issue and hold[ing] that prisoners are not “in custody” for the purpose of 28 U.S.C. § 2241 simply because the INS has lodged a detainer against them.”
• “‘Usually, ‘custody’ signifies incarceration or supervised release, but in general it encompasses most restrictions on liberty resulting from a criminal conviction.’”
• “Most of the circuit courts that have 15 considered the question have held that [an immigration] detainer does not place a prisoner in 16 ‘custody’ for purposes of habeas proceedings.”
• “Most of the circuit courts that have 11 considered the question have held that [an immigration] detainer does not place a prisoner in 12 ‘custody’ for purposes of habeas proceedings.”
• “Most of the circuit courts that have considered the question have 1 | held that [an immigration] detainer does not place a prisoner in ‘custody’ for purposes of habeas 2 | proceedings.”

Source: CourtListener parenthetical corpus (CC0).