S.R. v. Immigration and Customs Enforcement
Luis S.R. v. Immigration and Customs Enforcement; Eric Klang, in his official capacity as Sheriff of Crow Wing County, Minnesota; David Easterwood, in his official capacity as Acting Field Office Director of the Saint Paul Field Office, Enforcement and Removal Operations, U.S. Immigration & Customs Enforcement; Todd Lyons, in his official capacity as Acting Director of U.S. Immigration and Customs Enforcement; Markwayne Mullin, in his official capacity as U.S. Secretary of Homeland Security; and Pamela Bondi, in her official capacity as Attorney General of the United States
- Jerry Blackwell
- 0:26-cv-01482
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Luis S.R. v. Immigration and Customs Enforcement, Judge Blackwell accepted a magistrate judge's recommendation and denied the petition for release from immigration detention filed by Luis S.R.
Luis S.R., an individual held in immigration detention in or around Crow Wing County, Minnesota, whose petition for release from that detention was denied. Others in immigration detention who might seek similar relief could be affected by the legal reasoning in the underlying Report and Recommendation, though that reasoning is not detailed in this order.
What happened
In Luis S.R. v. Immigration and Customs Enforcement, No. 26-1482, a man identified as Luis S.R. filed a petition asking a federal court to order his release from immigration custody, arguing that his detention was unlawful. The case was referred to Magistrate Judge Elizabeth Cowan Wright, who issued a Report and Recommendation on March 26, 2026, concluding that the petition should be denied. Luis S.R. did not file any objections to that recommendation within the allowed time.
Because no objections were filed, the court reviewed the magistrate judge's recommendation only for obvious legal error — a more limited form of review than it would apply if objections had been raised. The court found no such error in the magistrate judge's analysis.
On April 6, 2026, Judge Jerry W. Blackwell accepted the Report and Recommendation in full and denied Luis S.R.'s amended petition for a court order requiring his release from detention. The court directed that judgment be entered against Luis S.R., meaning his request for release was rejected and the case is closed at the district court level.
The detailed version
- S.R. v. Immigration and Customs Enforcement · No. 0:26-cv-01482
- Jerry W. Blackwell
- Apr. 6, 2026
Background
Petitioner Luis S.R. filed an amended petition for a writ of habeas corpus — a court order challenging the lawfulness of a person's detention and seeking release — against Immigration and Customs Enforcement (ICE) and several named officials in their official capacities: Eric Klang (Sheriff of Crow Wing County, Minnesota), David Easterwood (Acting Field Office Director of ICE's Saint Paul Field Office), Todd Lyons (Acting Director of ICE), Markwayne Mullin (U.S. Secretary of Homeland Security), and Pamela Bondi (U.S. Attorney General).
Magistrate Judge's Report and Recommendation
The case was referred to United States Magistrate Judge Elizabeth Cowan Wright, who issued a Report and Recommendation (R&R) on March 26, 2026, recommending that the amended petition be denied. The opinion does not detail the specific legal basis for that recommendation; the text of the R&R itself is not reproduced in this order.
Review Standard
When a magistrate judge issues an R&R, parties have a limited time to file written objections. If no objections are filed, the district court reviews the R&R only for "clear error" under Federal Rule of Civil Procedure 72(b) — a deferential standard that requires the court to accept the magistrate's conclusions unless they are plainly wrong. Luis S.R. filed no objections within the permitted period. The district court applied the clear-error standard and found none.
Ruling
Judge Blackwell accepted the R&R in its entirety and denied Luis S.R.'s Amended Petition for a Writ of Habeas Corpus (Doc. No. 12). The court ordered that judgment be entered accordingly, closing the matter at the district court level.
What This Means Practically
The denial means the federal district court declined to order Luis S.R.'s release from immigration detention. Because the opinion itself does not reproduce the magistrate judge's analysis, the specific legal grounds for denial — such as jurisdiction, exhaustion of administrative remedies, or the merits of the detention — are not visible in this order alone.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.