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PETITION FOR WRIT OF HABEAS CORPUS AND COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

This habeas petition challenges the unlawful detention of a young man who, on the day he turned eighteen, was taken from a youth shelter with shackles around his wrists and ankles and sent to a maximum security jail facility that was intended to detain suspected gang members, individuals with violent convictions and people with mental health issues. Although his asylum pro bono attorney submitted documentation to ICE showing that he had a US citizen couple ready to sponsor him and offer him a safe home, ICE placed him in adult detention, in violation of a law that requires ICE to consider placing newly turned adults like Jose in the "least restrictive setting possible."