When Release is Not the End: Challenging Immigration Re-Detention
- Center for Human Rights and Constitutional Law

- Mar 25
- 1 min read
Updated: Mar 31
Across the country, immigrants who were previously released from detention after the government determined they were not a danger or a flight risk are increasingly being re-detained at ICE appointments and/or during their immigration proceedings – in other words, doing exactly what immigration agencies have asked them to do. These re-detentions are not based on any individualized re-assessment of flight risk or dangerousness, and they often occur without warning or any meaningful opportunity to challenge that loss of liberty.
The Center for Human Rights and Constitutional Law hosted a free CLE webinar, When Release is Not the End: Challenging Immigration Re-Detention, on Wednesday, March 25, 2026. Led by Monika Langarica, lead attorney on Fanfan v. Noem, this training examines the government’s growing use of immigration re-detention, the legal issues it raises, and the tools advocates are using to fight back, including habeas petitions and broader class action litigation challenging the practice.
The training highlights Fanfan v. Noem, a class action case being litigated by CHRCL and the Center for Immigration Law and Policy (CILP), which challenges ICE’s practice in San Diego of arbitrarily re-detaining immigrants when they appear for their ICE appointments. The discussion of Fanfan includes the temporary restraining order (TRO) granted in the case, as well as the pending motion for class certification and motion for preliminary relief under the APA.
Date of Training: Mar 25, 2026
The full presentation can be viewed here:
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