EDICSON v. DICKERSON, 4:25-cv-00050

Petitioner, a Venezuelan national, filed a habeas corpus petition after being detained at Stewart Detention Center in Georgia and subsequently removed to El Salvador.
Respondents argued the case is moot because Petitioner was no longer in U.S. custody following his transfer to El Salvador.
The Court granted Petitioner’s motion for expedited jurisdictional discovery to determine if the U.S. retains constructive custody over him.
Respondents sought stay or reconsideration of the discovery order, citing a D.C. District Court decision and requested limitation of discovery to materials already produced in the J.G.G. case.
The Court reviewed the materials, found them insufficient to resolve the issue, and determined further discovery on U.S.-El Salvador agreements and Petitioner’s status is warranted.
Court denied reconsideration but stayed discovery for 14 days pending potential appeal to the district judge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reconsideration of the discovery order is warranted	Discovery needed to assess U.S. custody, seeking specific agreements and facts	New D.C. case shows current evidence insufficient, discovery should be limited to J.G.G. materials	Denied reconsideration—Respondents did not meet standard
Whether U.S. retains constructive custody over Petitioner	U.S. control remains unclear; discovery needed	U.S. has no further control—El Salvador has sole authority	Further discovery warranted to clarify issue
Sufficiency of the J.G.G. documents as evidence	J.G.G. docs are incomplete, raise more questions	J.G.G. decision supports no constructive custody	J.G.G. material does not resolve U.S. control; more discovery needed
Court’s authority to order discovery in foreign relations context	Limited, targeted discovery is appropriate	Risk of improper judicial intrusion into sensitive diplomatic matters	Court can manage disclosures through protective tools; limited discovery appropriate

Am. Civil Liberties Union of Fla. v. City of Sarasota, 859 F.3d 1337 (11th Cir. 2017) (emphasizing the necessity of jurisdictional discovery where appropriate)
Kiyemba v. Obama, 561 F.3d 509 (D.C. Cir. 2009) (conclusiveness of government declarations on habeas jurisdiction)