Trump, President of the United States, et al. v. J. G. G. et al.
No. 24A931 · Decided April 7, 2025 · vacated
Whether the United States District Court for the District of Columbia had proper venue to issue injunctions preventing the removal of Venezuelan nationals under Presidential Proclamation No. 10903. Challenges to removal under the Alien Enemies Act must be brought via habeas corpus petitions in the district where the detainees are confined, rendering venue improper in the District of Columbia for the respondents' claims.
ON APPLICATION TO VACATE THE ORDERS ISSUED BY THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
Parties — Petitioner: TRUMP, PRESIDENT OF THE UNITED STATES, et al. · Respondent: J. G. G. et al.
Vote & lineupPer Curiam
Who prevailed — The petitioner prevailed in obtaining the vacatur of the District Court's temporary restraining orders.
The question

Whether the United States District Court for the District of Columbia had proper venue to issue injunctions preventing the removal of Venezuelan nationals under Presidential Proclamation No. 10903. Specifically, the Court addressed whether challenges to removals authorized by the Alien Enemies Act (AEA) must be brought via habeas corpus petitions in the district of confinement. The Court also considered what due process protections are required before such individuals are removed from the United States.

Petitioner's argument
  • Sought vacatur of temporary restraining orders (TROs) that prevented the removal of certain Venezuelan nationals designated as alien enemies.
  • Argued that challenges to removals under the Alien Enemies Act must be brought through habeas corpus proceedings rather than equitable relief in a district court.
  • Contended that venue for such challenges is limited to the district where the detainees are confined, which in this case is Texas, not the District of Columbia.
  • Agreed that members of Tren de Aragua subject to removal under the AEA are entitled to judicial review.
Respondent's argument
  • Sought injunctive and declaratory relief to prevent their removal from the United States under Presidential Proclamation No. 10903.
  • Challenged the Government's interpretation of the Alien Enemies Act and asserted that they do not fall within the category of removable "alien enemies."
  • Argued that summary removal without an individualized hearing violates the Constitution and various statutes.
  • Sought equitable relief to prevent their transfer to foreign prisons, specifically in El Salvador.
The decision
  • The Court granted the application to vacate the TROs, treating them as appealable injunctions under *Carson v. American Brands, Inc.*.
  • It held that challenges to removal under the Alien Enemies Act (AEA), Rev. Stat. § 4067, 50 U.S.C. § 21, must be brought in habeas corpus proceedings because the statute largely "preclude[s] judicial review" per *Ludecke v. Watkins*.
  • The Court reasoned that since these claims "necessarily imply the invalidity" of confinement and removal, they fall within the "core" of the writ of habeas corpus, citing *Nance v. Ward* and *Heck v. Humphrey*.
  • Applying *Rumsfeld v. Padilla*, the Court determined that jurisdiction for "core habeas petitions" lies exclusively in the district of confinement.
  • Because the respondents are confined in Texas, the Court concluded that venue was improper in the District of Columbia.
  • Regarding due process, the Court noted that the Fifth Amendment entitles aliens to due process of law in removal proceedings under *Reno v. Flores*.
  • Invoking *Mullane v. Central Hanover Bank & Trust Co.*, the Court held that detainees are entitled to notice and an opportunity to be heard "appropriate to the nature of the case."
  • Specifically, the Court required that AEA detainees receive notice within a reasonable time and in a manner allowing them to seek habeas relief in the proper venue before removal occurs.
Separate opinions
KAVANAUGH, concurring, joined by nobody
  • Argues that claims regarding transfers must be brought under habeas corpus rather than the Administrative Procedure Act (APA).
  • Cites *LoBue v. Christopher*, *Kiyemba v. Obama*, and the Habeas Corpus Act of 1679 as precedent for using habeas to review transfer claims.
  • Invokes 5 U.S.C. § 704, noting that APA claims are unavailable when another "adequate remedy in a court" exists.
SOTOMAYOR, dissenting, joined by KAGAN and JACKSON (and BARRETT as to Parts II and III–B)
  • Argues the Court lacks jurisdiction over interlocutory TROs under *Carson v. American Brands, Inc.* unless there is an "irreparable... consequence."
  • Contends that these claims do not "sound" in habeas because they do not seek release from custody but rather protection from deportation, citing *Preiser v. Rodriguez*, *Heck v. Humphrey*, and *Skinner v. Switzer*.
  • Asserts the APA should be available for review of agency action absent specific congressional preclusion, citing *Abbott Laboratories v. Gardner*, *Bowen v. Massachusetts*, and *Darby v. Cisneros*.
  • Argues the Government lacks "clean hands" under *Precision Instrument Mfg. Co. v. Automotive Maintenance Machinery Co.* due to its alleged efforts to evade judicial review.
JACKSON, dissenting, joined by SOTOMAYOR
  • Criticizes the Court's use of the emergency docket to decide complex legal issues without oral argument or full merits briefing.
  • Argues that deviating from standard judicial processes increases the risk of error and lacks transparency.