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Wendy Osorio Martinez v. Attorney General United States
Citation: Not availableDocket: 17-2159
Court: Court of Appeals for the Third Circuit; June 18, 2018; Federal Appellate Court
Original Court Document: View Document
Petitioners, consisting of four children from Salvadoran and Honduran backgrounds and their mothers, appeal for the second time regarding their expedited removal orders. In a previous case (Castro v. United States Department of Homeland Security), the court determined it lacked jurisdiction to review their claims under the Immigration and Nationality Act (INA) due to the petitioners' insufficient ties to the United States, which were limited to a brief presence before their apprehension. The District Court's dismissal was affirmed. Now, the petitioners present their claims again, but with a significant change: the children have been granted Special Immigrant Juvenile (SIJ) status, a classification aimed at protecting abused, abandoned, or neglected minors and providing them certain rights, such as eligibility for lawful permanent residency and procedural safeguards against revocation of their status. Despite the change in circumstances, the court finds that the INA still prohibits its review of the case, similar to the previous decision in Castro. A novel legal question arises regarding whether the INA's jurisdiction-stripping provision constitutes an unconstitutional suspension of habeas corpus for SIJ designees seeking judicial review of expedited removal orders. The court concludes that it does. Aliens who establish sufficient connections to the U.S. can invoke constitutional protections, as determined in Castro. The eight Petitioners—Wendy Amparo Osorio-Martinez and her three-year-old child, Carmen Aleyda Lobo Mejia and her four-year-old child, Maria Delmi Martinez Nolasco and her seven-year-old child, and Jethzabel Maritza Aguilar Mancia and her sixteen-year-old child—fled gang-related violence from Honduras and El Salvador. They entered the U.S. in late 2015, were apprehended by Customs and Border Patrol, and subsequently detained. After being ordered expedited removal under 8 U.S.C. § 1225(b)(1), their asylum requests, based on fear of violence, were denied by DHS and affirmed by an Immigration Judge. In late 2015, the Petitioners, along with additional families, sought habeas relief, contesting the expedited removal orders' legality and the procedures applied during their credible fear interviews. Their claims were dismissed by the District Court, which ruled that it lacked subject-matter jurisdiction. The key issues considered in Castro focused on whether the Immigration and Nationality Act (INA) stripped jurisdiction for reviewing the claims and the implications for the Suspension Clause of the Constitution. The asylum requests were denied due to a failure to demonstrate a required nexus for eligibility, rather than due to credibility issues. The court concluded it lacked jurisdiction under the INA and that the Petitioners could not invoke the Suspension Clause, as recent entrants seeking initial admission lacked constitutional rights regarding their admission applications. This seemingly concluded the legal options for the Castro petitioners. However, the current Petitioners, having met the eligibility criteria for Special Immigrant Juvenile (SIJ) status, possess the rights necessary to enforce their protections under the Suspension Clause, leading to the reversal of the District Court’s denial of their request for injunctive relief. Four children sought Special Immigrant Juvenile (SIJ) status while the Castro litigation was ongoing, obtaining orders from the Berks County Court that reunification with their parents was not viable due to abuse, neglect, or abandonment, and that returning them to their country of origin was not in their best interest. With these court orders, they petitioned the United States Citizenship and Immigration Services (USCIS), which approved their petitions in late 2016, granting them SIJ status with the Secretary of Homeland Security's consent. This status allowed them to apply for adjustment of status to lawful permanent resident, although necessary visas were not available at that time due to congressional limits, resulting in a waiting list exceeding two years. Despite the SIJ status, the Department of Homeland Security (DHS) continued to detain the children and their mothers, seeking expedited removal to their countries of origin—contrary to the previous findings of both USCIS and the Berks County Court. Historically, DHS had not attempted to remove SIJ-classified children, especially not on an expedited basis. Responding to this situation, the Petitioners filed a class action complaint for a writ of habeas corpus or an injunction against their removal and detention, arguing that their SIJ classification prohibited such actions and asserting violations of their constitutional rights under the Equal Protection and Due Process Clauses, the Immigration and Nationality Act, the Foreign Affairs Reform and Restructuring Act, and the Administrative Procedure Act. They also pursued a Bivens action for illegal detention under the Fifth Amendment. Initially, the District Court granted a temporary restraining order (TRO), but after reassignment to another judge, the TRO was dissolved, and the court declined to issue a preliminary injunction, citing a lack of subject-matter jurisdiction. The court interpreted the earlier Castro case as a barrier to the Petitioners' success on the merits. An appeal followed, and by September 2017, the Petitioners were released from detention after the TRO was dissolved and the case was briefed. Immigration Judges (IJs) conducted bond hearings for Petitioners, overruling the Government's objections, and decided on their release under "conditional parole" per 8 U.S.C. § 1226(a)(2)(B). The IJs deemed the nearly two-year imprisonment of Petitioners unjustifiable, lacking any rational basis. Following this, the Government appealed, resulting in a stay from the Board of Immigration Appeals (BIA); however, as of the case's argument, Petitioners remained free. The standard of review for preliminary injunctions involves reviewing factual findings for clear error, legal conclusions de novo, and assessing the decision to grant or deny injunctions for abuse of discretion. Jurisdiction is also a key issue, with the Government arguing that this case parallels a previous case, Castro, which limits jurisdiction under § 1252(e)(2). While the argument holds for jurisdiction, it does not negate the constitutional implications of this provision for Special Immigrant Juvenile (SIJ) designees. Petitioners can demonstrate an actual injury that could be remedied by the court, such as vacating expedited removal orders. Historical precedents support that an order of removal has significant collateral consequences, including a five-year inadmissibility period for Petitioners if removed. The Government’s assertion that SIJ classification doesn’t change Petitioners’ legal status is countered by the INA, which recognizes SIJ as a distinct status conferring various rights and protections. The analysis will first examine jurisdiction under the INA, followed by the constitutionality of § 1252(e)(2) relative to the Suspension Clause, and finally, the implications for Petitioners’ request for a preliminary injunction. The situation arises from the intersection of expedited removal procedures and federal court access limitations established by Congress. Petitioners assert that certain aliens, specifically Special Immigrant Juvenile (SIJ) designees, are entitled to special immigrant classifications under Congress's provisions, which grant them a protected status that cannot be revoked without due process, including judicial review. This is supported by relevant statutes such as 8 U.S.C. § 1101(27)(J) and § 1255(h), modified by the Trafficking Victims Protection Reauthorization Act of 2008, and 8 C.F.R. § 205.2. The children claim that their SIJ status exempts them from the expedited removal process outlined in § 1252(e)(2), allowing for court review of their removal orders. The excerpt outlines the general framework for expedited removal proceedings under the Immigration and Nationality Act (INA), which allows for the swift removal of aliens deemed inadmissible without the procedural protections of standard removal proceedings, such as the right to present evidence or appeal. Key criteria for expedited removal include the alien being either arriving in the U.S. or lacking two years of continuous presence, not having been admitted or paroled, and either lacking valid documentation or having made a misrepresentation. Judicial review of expedited removal orders is severely limited to specific grounds: confirming the individual's status as an alien, verifying whether an expedited removal order was issued, and determining if the individual has been granted legal permanent residency, refugee, or asylum status. The statute restricts the inquiry into whether an order was issued to confirming its existence and relation to the petitioner, while barring any claims related to the implementation of expedited removal orders. Expedited removal imposes strict limitations on an alien’s future admission to the U.S. An alien ordered removed under expedited removal provisions becomes inadmissible for 5 years when seeking re-entry, and if they reenter without admission, their inadmissibility extends to 10 years. Special Immigrant Juvenile (SIJ) status was created in 1990 to safeguard abused, neglected, or abandoned children who entered the U.S. illegally. Eligibility for SIJ status requires a juvenile court determination that returning to the child’s country of last habitual residence is not in their best interest, along with dependency on the court or state custody. Approval from USCIS and consent from the Secretary of Homeland Security are also necessary. SIJ classification provides significant benefits, including being considered as paroled into the U.S. for adjustment of status purposes and exemption from certain inadmissibility grounds. Notably, SIJ designees are exempt from inadmissibility due to lack of valid entry documents, which is relevant to the Government's expedited removal claims against some petitioners. SIJ designees enjoy access to educational programs, preferential treatment for employment-based visas, and protections against revocation of status, which can only occur after a notice and hearing process where the designee can contest the revocation. Additionally, SIJ designees have the right to appeal adverse decisions first to the Associate Commissioner for Examinations and subsequently to federal courts if they claim legal wrong due to agency action. Petitioners assert that their Special Immigrant Juvenile (SIJ) status qualifies them for an exception to the judicial review bar under § 1252(e)(2) regarding expedited removal orders. They claim that, having obtained SIJ status, they are deemed “paroled” into the United States, thus disputing their classification as “ordered removed.” While discretionary decisions by the Attorney General are not subject to judicial review, federal courts may review whether an agency has adhered to its own regulations and policies under the Administrative Procedure Act. However, precedent set in Castro indicates that judicial review is limited to confirming whether an expedited removal order was actually issued and if it pertains to the petitioner. The court emphasized that Congress intended to restrict judicial review concerning expedited removal orders, and Petitioners' claims extend beyond these narrow grounds. They challenge the application of the order rather than its issuance or applicability to them, which contradicts the narrow inquiry permitted under Castro. Additionally, the court noted that a similar argument regarding parole status was rejected in Castro, which dismissed reasoning from a previous case where petitioners contested their eligibility for expedited removal. The court sided with the petitioners regarding the interpretation of § 1252(e)(5), which assesses whether an expedited removal order pertains to the petitioner. The court concluded that the review of lawful application involves evaluating whether such an order has been issued against the individual. However, in Castro, the court found this interpretation unsupported and contradictory to the statute's language. Petitioners argued they were not contesting the expedited removal orders themselves but rather the government's actions post-issuance that could lead to a de facto revocation of their Special Immigrant Juvenile (SIJ) status. Despite this, § 1252 prohibits courts from reviewing the orders and any claims related to their implementation. The term "relating to" is interpreted broadly within the immigration context, indicating that the petitioners' claims regarding their SIJ status are connected to the removal orders. Thus, their request for a judgment deeming the orders unenforceable falls under the jurisdiction-stripping provision of § 1252. Additionally, the document raises a constitutional question regarding whether this jurisdiction-stripping violates the Suspension Clause, which prohibits the suspension of habeas corpus except in cases of rebellion or invasion. The court will analyze this issue using a two-step process established by the Supreme Court in Boumediene v. Bush, focusing on whether the petitioners are barred from invoking the Suspension Clause due to their circumstances or attributes. Justice Thomas contended in a concurrence that the Suspension Clause should not apply to alien-petitioners who seek bail hearings and only request declaratory and injunctive relief without invoking § 2254 or seeking release from custody, as noted in *Jennings v. Rodriguez, 138 S. Ct. 830, 858 (2018)*. Although this view has not been embraced by a majority of the Court, it is irrelevant here because Petitioners did seek habeas relief in their initial complaint. Their request for a stay of expedited removal orders is ancillary to their primary objective of obtaining release from detention and removal under § 1225(b)(1). Following the precedent set in *Castro, 835 F.3d at 445,* the adequacy of substitutes for habeas relief must be evaluated to determine the legality of detention or removal. In *Castro*, it was ruled that the Suspension Clause was not violated for aliens apprehended shortly after entering the country, who were denied review of expedited removal orders. The court held that such petitioners could not challenge the jurisdiction-stripping provisions of the Immigration and Nationality Act (INA) based solely on physical presence. However, it did indicate that future courts could assess the Suspension Clause rights of aliens with more significant ties to the U.S. In this context, the Petitioners, who possess SIJ status indicating substantial connections to the country, can invoke the Suspension Clause and seek habeas corpus relief. The expedited removal process does not provide adequate substitute procedures, leading to an unconstitutional suspension of the writ concerning these Petitioners. The analysis follows the steps outlined in *Boumediene*. The first step assesses whether Petitioners are barred from invoking the Suspension Clause due to their status or the circumstances of their detention. In *Castro*, it was determined that aliens seeking initial admission to the U.S. have no constitutional rights regarding their application, based on the Supreme Court's interpretation. This principle implies that aliens apprehended shortly after entering the U.S. cannot invoke the Suspension Clause. The distinction between seeking admission and being physically present in the U.S. is crucial, particularly considering the legislative changes made by the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, which redefined "admission" in terms of lawful entry. The legal distinction between “admission” and “entry” is emphasized, highlighting that certain aliens seeking entry cannot invoke constitutional protections, including the Suspension Clause, as established in previous cases like Sale v. Haitian Ctrs. Council, Inc. The excerpt underscores that while aliens on the threshold of entry lack due process protections related to admission, Special Immigrant Juvenile (SIJ) designees are different. They are recognized as having developed substantial connections with the United States, as established in Castro, which cites Supreme Court rulings affirming that aliens gain constitutional rights upon developing ties to the country. The analysis cites several precedents indicating that rights increase with an alien's integration into society. It notes that while mere physical presence is insufficient for constitutional protections, SIJ designees possess significant ties due to their status as wards of the state, eligibility for statutory protections, and their pending applications for permanent residence. The conclusion drawn is that SIJ designees have established a substantial legal relationship with the U.S., aligning with Congress’s authority over immigration matters, allowing them to invoke certain constitutional protections. Eligibility for Special Immigrant Juvenile (SIJ) status is geared towards supporting a specific group of abused children, allowing them to remain in the U.S. and apply for lawful permanent resident (LPR) status. Applicants must be declared dependent on a juvenile court in the U.S. or placed under state agency custody, and reunification with one or both parents must be unfeasible due to abuse, neglect, or abandonment. SIJ status is designed to provide humanitarian protection for these vulnerable child immigrants, reflecting Congressional intent to limit benefits to those specifically affected. To qualify, applicants must be physically present in the U.S., unmarried, and under 21 years old, and they need an order of dependency from a state juvenile court before applying to USCIS. This order must affirm that the applicant is dependent on the court or in state agency custody, that returning them to their home country is not in their best interest, and that reunification with parents is not viable due to abuse or neglect. Additionally, these findings must be aligned with state law, which may impose specific residency requirements. The petitioners in this case resided in Pennsylvania for over six months prior to seeking their dependency declarations, satisfying the state’s residency criteria. To obtain Special Immigrant Juvenile (SIJ) status in Pennsylvania, applicants must reside in the state for at least six months before seeking a predicate order from state courts. Following the receipt of this order, they must submit an application to USCIS with sufficient evidence of eligibility and the required filing fee. The Secretary of Homeland Security also needs to consent to the granting of SIJ status, which acknowledges the applicant's dependency status. States may impose additional requirements beyond those specified in the SIJ statute, emphasizing the necessity of demonstrating a strong independent relationship with the state. For instance, certain cases require proof that reunification with neither parent is feasible, and that the abuse involved was not too remote in time. SIJ classification is intended to ensure that benefits are sought primarily to escape abuse, neglect, or abandonment. This classification underscores the dependency of SIJ designees on both state and federal authorities, highlighting the risks they face if returned to their countries of origin. The legal framework surrounding SIJ status reflects Congress's intent to provide abused, neglected, or abandoned children with a recognized legal relationship with the United States, ensuring they are afforded due process in maintaining and deepening that connection. The SIJ status is deemed to facilitate their adjustment of status to lawful permanent residency, reinforcing their established ties to the country. SIJ (Special Immigrant Juvenile) designees are classified as “deemed paroled” under 8 U.S.C. 1255(h)(1), which Petitioners argue exempts them from expedited removal, as this process applies only to aliens who have not been admitted or paroled. The term “deemed” is interpreted in its plain meaning, aligning with its usage elsewhere in the Immigration and Nationality Act (INA). While the Government contends that this designation serves merely as a legal fiction for determining eligibility for immigrant visas under 1255(a), and not as actual parole, it recognizes that Congress intended to provide SIJ designees significant benefits, differentiating them from other aliens. SIJ designees are exempt from the general requirement of being “admitted or paroled” for adjustment of status under 1255(a), as explicitly stated in the statute. Additionally, they are shielded from various grounds of inadmissibility and granted numerous statutory benefits, including access to educational programs and preferential employment visa status. Furthermore, Congress established procedural protections for SIJ status, requiring that any revocation be justified by “good and sufficient cause” and accompanied by notice to the designee, ensuring due process rights are upheld. Revocation of Special Immigrant Juvenile (SIJ) status requires a written notification stating specific reasons and the option to appeal within the agency, per 8 C.F.R. 205.2. SIJ designees can seek judicial review of agency actions not committed to discretion, including the application of SIJ criteria and procedural compliance, as established in case law (e.g., Quarantillo, Yeboah, Ghaly). However, expedited removal can occur without cause or notice, undermining the protections afforded to SIJ designees. Once removed, these individuals cannot adjust their status due to requirements for physical presence in the U.S. and are subject to a five-year reentry bar. Although the Director of USCIS can waive inadmissibility, this decision is discretionary, lacks a processing timeline, and incurs significant costs. Expedited removal is based on grounds of inadmissibility that SIJ status should exempt individuals from, effectively nullifying their rights. Additionally, expedited removal raises constitutional due process concerns, as due process protections attach to the statutory rights granted to SIJ designees, which must be respected in agency decisions regarding dependency hearings. Approval of waivers for Petitioners will not alleviate the backlog of available visas, which the Government indicates is currently at least two years. There is no assurance that such waivers will be granted. While Congress holds the power to create statutory rights related to immigration status, the Executive branch has historically respected these rights, allowing Special Immigrant Juvenile (SIJ) designees to remain in the U.S. while their status applications are pending. The Immigration and Nationality Act (INA) permits the Department of Homeland Security (DHS) to remove certain aliens within two years of entry, but it has generally refrained from initiating removal proceedings against SIJ designees during their application process. Recent presidential directives have suggested applying expedited removal proceedings to some aliens, but there has been no formal policy announcement from the Secretary of DHS regarding SIJ designees. Current policy requires that if an SIJ is in removal proceedings, those proceedings must be terminated before an adjustment application can be adjudicated. The Board of Immigration Appeals (BIA) has asserted that applicants for SIJ status should not be removed unless ineligible, advocating for the continuation of proceedings until a state dependency petition is resolved. Additionally, the Chief Immigration Judge has instructed that cases involving unaccompanied children seeking SIJ status must be administratively closed or postponed for the appropriate state court process. Recent directives from the Attorney General emphasize that cases should only be administratively closed if explicitly permitted by regulation or judicial agreement, and that cases not proceeding should be terminated. Petitioners with Special Immigrant Juvenile (SIJ) status possess minimum due process rights, distinguishing their situation from precedents like Castro, which dealt with aliens apprehended at entry points without constitutional claims. Unlike the Cold War-era cases of Knauff and Mezei, where aliens at the threshold were denied constitutional rights, the current context involves individuals who have been granted statutory relief from removal, akin to the circumstances in Khouzam v. Attorney General. The legal relationship between SIJ designees and the U.S. is significant, as it establishes a basis for seeking continuances in their proceedings. SIJ designees are closer to lawful permanent resident (LPR) status than to newly apprehended aliens, suggesting they are on the verge of adjusting their status, pending visa availability and approval. Furthermore, while the extent of Petitioners' rights under the Due Process and Suspension Clauses remains unclear, it is noted that those with SIJ status are not barred from invoking the Suspension Clause. LPRs exemplify individuals entitled to comprehensive constitutional protections, marking a critical distinction for SIJ designees. Individuals may not be deprived of life, liberty, or property without due process. Once immigrant visas are available and Petitioners achieve lawful permanent resident (LPR) status, they fall outside the jurisdiction-stripping provision of the Immigration and Nationality Act (INA), allowing for judicial review of any removal orders against them. Although adjustment of status is discretionary and not automatically granted upon obtaining Special Immigrant Juvenile (SIJ) status, the government has not indicated any reasons for potential denial in this case. The absence of LPR status or potential inadmissibility does not preclude an alien from claiming constitutional protections regarding admission. Courts have recognized that even undocumented aliens with significant ties to the U.S. can challenge their legal status. Petitioners, having pursued their rights as SIJ designees for nearly two years, are close to receiving their visas, indicating their substantial connection to the U.S. The concept of physical presence is relevant in assessing an alien's constitutional rights, as noted in prior cases. The plenary power doctrine allows the government discretion over immigration decisions, but this power is not absolute and is subject to constitutional limitations in certain contexts. Courts have the authority to determine if Congress has used constitutionally acceptable methods in exercising its powers, as established in Zadvydas and Chadha. In Castro, a distinction was made between aliens seeking initial admission, who have no constitutional claims, and those with significant ties to the U.S., who are entitled to protections, including habeas corpus rights under the Suspension Clause. The Petitioners in this case belong to the latter group, having met Special Immigrant Juvenile (SIJ) criteria, being recognized as dependents of the State, and granted various rights by Congress, including adjustment of status once visas are available. The plenary power of Congress does not limit the use of the Suspension Clause in this context. The expedited removal process sought by the Attorney General could undermine the rights established for SIJ designees and is inconsistent with Congressional authority over immigration. Historically, the Executive has acknowledged the special status of SIJ applicants by requiring that removal proceedings be halted for their adjustment applications to be processed. Furthermore, while Congress has broad powers regarding the admission of aliens, this plenary power is intended to protect, not deny, the Petitioners’ rights, and they are not seeking to extend judicial review beyond what Congress has authorized. Instead, they aim to enforce the rights granted by Congress in the appropriate state or juvenile court. Judicial deference to the Attorney General’s discretion is emphasized, particularly in the context of immigration policy, which is exclusively within Congress's purview. Petitioners argue that the Attorney General is exceeding authority granted by Congress under the Immigration and Nationality Act (INA), which is not a discretionary matter. The Executive Branch must adhere to procedural due process safeguards. Consequently, Petitioners retain the right to habeas corpus, allowing the inquiry to continue. The second step of the Boumediene analysis involves assessing whether the statute stripping jurisdiction offers adequate substitute procedures for habeas corpus. The statute in question fails to provide an "adequate and effective" alternative for habeas review, as established by precedent. The Supreme Court has noted that habeas review is particularly urgent in cases of executive detention. Effective habeas review requires the court to have the authority to assess both the reasons for detention and the Executive’s power to detain. Historically, habeas corpus has been a mechanism to scrutinize the legality of executive detention, granting prisoners the opportunity to demonstrate any erroneous application of relevant law. However, the jurisdiction-stripping provisions of the INA allow habeas review only on three narrow issues: the petitioner's alien status, the issuance of a removal order, and the ability to prove lawful status. These provisions explicitly limit review concerning admissibility or relief from removal, obstructing the ability to evaluate whether the expedited removal statute was lawfully applied. Thus, the statute does not meet even the most basic requirements for review demanded by the writ of habeas corpus, leading to the conclusion that further inquiry is unnecessary due to the deficiencies identified. The legal document emphasizes that even if the question were closer, guidance from Boumediene supports the conclusion that Petitioners can invoke habeas corpus privilege, and that the Immigration and Nationality Act (INA) fails to provide adequate substitute procedures, leading to a violation of the Suspension Clause as applied to them. Consequently, the District Court retains jurisdiction to consider the Petitioners' claims on remand. Regarding temporary injunctive relief, the District Court believed it lacked jurisdiction to issue a writ of habeas corpus or to enjoin Petitioners’ removal, citing the inability of the Petitioners to meet the standard for injunctive relief without subject-matter jurisdiction for habeas review. The document references the criteria from Boumediene and Luna v. Holder, which assess whether substitute procedures expedite or hinder detainee claims, their susceptibility to government manipulation, and the adequacy of the reviewing entity’s authority. It also outlines the criteria for obtaining a preliminary injunction, which include demonstrating a likelihood of success on the merits, suffering irreparable harm, and balancing equities in the moving party's favor. The document concludes that the District Court erred in dissolving the temporary restraining order (TRO) and denying the Petitioners' motion for injunctive relief, highlighting a clear likelihood of success on their habeas petition. It asserts that remanding is unnecessary given the clarity of the legal outcome. Judicial economy advises against unnecessary removal actions. SIJ (Special Immigrant Juvenile) designees possess specific rights, such as applying for LPR (Lawful Permanent Resident) status and protections against the revocation of their SIJ status without due process. Executing expedited removal orders would infringe upon these rights. The juvenile court determined that returning the child to their country of origin was not in their best interest due to parental abuse, neglect, or abandonment, which fulfills the requirement of irreparable harm. While recognizing the public interest in executing removal orders promptly, the government's previous inaction regarding SIJ applicants diminishes the urgency of removal. The Secretary of Homeland Security's approval of SIJ applications signifies an acknowledgment of the need for protection from abuse or neglect. Upholding statutory and constitutional rights and allowing for meaningful judicial review aligns with public interests. Consequently, the court will reverse the District Court's denial of the Petitioners' request for injunctive relief and remand for further proceedings. Although the relief is limited to minor Petitioners, the record highlighted a lack of justification for the prolonged detention of one Petitioner and their mother. The Immigration Judge emphasized the ability to parole the mother for the child's psychological well-being, referencing specific regulations governing the release of detained children.