This case challenges the immigration detention and attempted removal of young people who have been abused or neglected by their own parents. Carlos Guerra Leon is an 18- year-old recent high school graduate who works at a car wash in New York.

He also has Special Immigrant Juvenile Status (SIJS), a humanitarian visa for young people found by a court to have been abused or neglected by their own parents. A young person with SIJS is supposed to be immediately eligible for lawful permanent residence. But a government backlog in applications means thousands of young people with SIJS, like Carlos, are still waiting to receive permanent immigration status. Under a government policy called deferred action, these young people cannot be removed for a renewable period of four years while they wait for lawful permanent residence.

But in August 2025, immigration officers arrested Carlos without a warrant while he was on his way to work from home. They detained him in Louisiana and argued in court that they can still deport Carlos, even though he has SIJS and deferred action.

What is the legal argument in this case?

Under the Due Process Clause of the U.S. Constitution’s Fifth Amendment, the only reasons someone can be held in immigration detention are to control danger to the community or risk of flight prior to removal. But a person with deferred action, like Carlos, cannot be removed. Because his detention cannot be for the purpose of controlling flight prior to removal, it violates the Due Process Clause.

The U.S. Constitution’s Fourth Amendment, and immigration regulations, require that an immigration officer conducting a warrantless arrest have reason to believe the person he arrests is violating the immigration laws or is likely to escape before a warrant can be obtained. Carlos has SIJS and deferred action and was traveling from his stable home address to his stable work address, where an officer would have been able to find him at a later time. Therefore, no officer could hold a reasonable belief that Carlos was violating immigration laws and that he was likely to escape before a warrant could be obtained.

What is the status of this case?

On October 30, 2025, the district court granted a temporary restraining order and ordered that Carlos be released from detention. The court found that Carlos is likely to succeed on his argument that because people with deferred action cannot be removed, they cannot be detained for removal.

The case provides authority for a rule that protects thousands of people with deferred action from detention and removal.