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3rd Circuit Vacates Order Freeing Columbia Activist Mahmoud Khalil, Restoring Path to Removal

The 2-1 ruling directs him to seek any relief through the immigration appeals process because district courts lack jurisdiction over his habeas petition.

Overview

  • Judges Thomas Hardiman and Stephanos Bibas formed the majority with Judge Arianna Freeman dissenting, holding that the Immigration and Nationality Act channels review to a petition for review after a final removal order.
  • The panel vacated Judge Michael Farbiarz’s prior release and injunction orders and remanded with instructions to dismiss Khalil’s habeas case for lack of subject‑matter jurisdiction.
  • The opinion did not decide Khalil’s First Amendment retaliation claims, stating those arguments must be presented within the immigration system and any subsequent federal appeal.
  • The decision reopens the possibility of re-detention and deportation but does not take immediate effect as Khalil’s lawyers pursue further review, including a potential en banc or Supreme Court appeal.
  • Khalil was arrested by ICE on March 8, 2025, later released in June, and an immigration judge has found him deportable with potential removal to Algeria or Syria under foreign-policy and misrepresentation theories he disputes.