Coreas v. Bounds, 451 F.Supp.3d 407

Petitioners Mauricio Coreas and Angel Guzman Cedillo are high‑risk immigration detainees (diabetes; hypertension/other conditions) held by ICE at Howard County Detention Center (HCDC) and Worcester County Detention Center (WCDC) who sought immediate release via a § 2241 habeas petition/TRO due to COVID‑19 risk.
Petitioners alleged detention conditions (shared dorms/cells, communal spaces, limited cleaning/supplies, staff movement) create heightened risk and that facilities lacked testing capability; some mitigation steps were adopted after suit (screening, reduced populations, soap/sanitizer claims disputed).
District Court held a video hearing and evaluated standing, availability of § 2241, and TRO factors under Winter; Respondents argued lack of standing, inappropriate habeas vehicle, and adequate mitigation.
Court found Petitioners have Article III standing and that § 2241 can be used by immigration detainees seeking release for unconstitutional conditions, but declined to grant a TRO at that time.
The denial was without prejudice: the court will grant relief (or find a likelihood of success) if COVID‑19 is confirmed in either facility or if Respondents fail to file a Testing Certification that they possess tests and will test symptomatic individuals by April 8, 2020; Petitioners may renew the TRO under those conditions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing	Petitioners face imminent risk of COVID‑19 infection and therefore injury	No confirmed cases in facilities, so risk is speculative	Court: standing satisfied; risk is imminent given congregate settings and expert evidence
Proper vehicle: § 2241 habeas	Habeas appropriate because remedy sought is immediate release	Conditions‑of‑confinement challenge better as civil rights action	Court: § 2241 available for immigration detainees seeking release based on unconstitutional conditions
Likely success on merits (deliberate indifference/conditions)	Failure to protect high‑risk detainees, lack of testing, no social distancing, no special measures for high‑risk detainees	Facilities adopted mitigation (screening, suspension of visits, cleaning supplies, reduced populations) and have no confirmed cases	Court: Not likely to succeed now given no confirmed cases and steps taken; would find likelihood if COVID‑19 is present in facility or if no Testing Certification is provided
TRO factors (irreparable harm, balance, public interest)	Infection poses serious, potentially fatal, irreparable harm to high‑risk detainees; public interest favors protecting constitutional rights	Government interest in immigration enforcement and mandatory detention for these detainees	Court: If likelihood of success established, irreparable harm and public interest would favor release; on current record balance does not support TRO

Hollingsworth v. Perry, 570 U.S. 693 (standing principles for Article III)
Susan B. Anthony List v. Driehaus, 573 U.S. 149 (imminence standard for injury‑in‑fact)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing elements)
Preiser v. Rodriguez, 411 U.S. 475 (habeas vs. civil rights remedies)
Ziglar v. Abbasi, 137 S. Ct. 1843 (limits on conditions‑of‑confinement habeas guidance)
Zadvydas v. Davis, 533 U.S. 678 (use of habeas for immigration detention challenges)
Helling v. McKinney, 509 U.S. 25 (Eighth Amendment: risk of future harm from communicable disease)
Youngberg v. Romeo, 457 U.S. 307 (due process protections for civil detainees)
Estelle v. Gamble, 429 U.S. 97 (deliberate indifference standard for inadequate medical care)
Farmer v. Brennan, 511 U.S. 825 (subjective knowledge/deliberate indifference)
Hill v. Nicodemus, 979 F.2d 987 (4th Cir.: deliberate indifference applies to pretrial detainee medical claims)
Matherly v. Andrews, 859 F.3d 264 (4th Cir.: standard for punitive conditions in civil detention)
Raynor v. Pugh, 817 F.3d 123 (4th Cir.: humane conditions and adequate medical care requirement)
Winter v. Natural Resources Defense Council, 555 U.S. 7 (preliminary injunction/TRO standard)