Flores Salazar v. Moniz, 1:25-cv-11159

Jeanfranco Alejandro Flores Salazar, a Venezuelan national, was paroled into the U.S. in July 2024 by CBP for humanitarian reasons while he sought asylum, and issued valid work authorization.
After compliant, lawful status and no criminal history, Flores Salazar was erroneously detained by CBP and ICE in March 2025 while working in Maine, despite presenting valid documents.
Flores Salazar spent 65 days in immigration detention and was released only after filing a federal habeas petition but remained subject to intensive GPS-monitored supervision.
The government admitted his detention was a result of "human error" and "administrative oversight" and that there was no lawful basis for his arrest or ongoing restraint.
Flores Salazar challenged both the initial detention and ongoing supervision as unlawful, seeking release and attorney's fees under the Equal Access to Justice Act.
The government moved to dismiss, contending habeas relief was moot since he was no longer incarcerated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of Petition	Supervision conditions amount to custody, so habeas relief is not moot.	No longer in ICE custody; only minor supervision remains.	Petition is not moot—supervision amounts to custody.
Lawfulness of Detention	Detention lacked any lawful basis; parole remained valid and unrevoked at time of arrest.	No substantive defense on merits; cited mootness only.	Detention and supervision were unlawful. Release ordered.
Jurisdiction Post-Release	Court retains jurisdiction even with changing ICE supervision and locations, citing continuous legal custody.	Implied jurisdictional challenge via mootness argument.	Court retains jurisdiction to order relief.
Attorney’s Fees	Sought fees as prevailing party under EAJA due to unlawful government conduct.	No argument at this stage; ordered to show cause.	Government must show cause why fees should not be awarded.

Rumsfeld v. Padilla, 542 U.S. 426 (District court retains jurisdiction over habeas petitions after a petitioner is moved; can direct relief to those with legal control.)
Ex parte Endo, 323 U.S. 283 (Habeas relief not defeated by changes in physical custodian; courts may direct release to the entity with authority.)