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Third Circuit Vacates Release of Columbia Activist Mahmoud Khalil, Orders Habeas Case Dismissed

The ruling requires any constitutional or detention claims to proceed through a petition for review after a final removal order.

Overview

  • By a 2-1 vote, the appeals panel said the New Jersey district court lacked subject-matter jurisdiction under the Immigration and Nationality Act to order Khalil’s release.
  • The court vacated the June 2025 habeas-based release and directed dismissal of the petition, raising the prospect of re-detention as his immigration case continues.
  • Judge Arianna Freeman dissented, arguing the district court could hear Khalil’s now-or-never claims and that he showed irreparable injury from detention.
  • Judges Thomas Hardiman and Stephanos Bibas formed the majority, calling the INA’s petition-for-review pathway the proper forum once a final removal order issues.
  • An immigration judge has found Khalil removable to Algeria or Syria, a decision under administrative appeal, while Khalil’s lawyers vow further court challenges.