U.S. District Judge John deGravelles found former Baltimore ICE field director Vernon Liggins in contempt of court Wednesday for the arrest of a Baltimore-area resident despite a court order. DeGravelles awarded modest compensatory damages in addition to attorneys’ fees to Ibrahim Mohammed, an Ethiopian man who has spent the last 13 months in and out of ICE custody. This contempt finding signals what happens when ICE ignores judicial release directives—and what practitioners can expect when defending habeas claims.
What changed
ICE arrested Mohammed and held him in custody for months in a maximum-security prison in Louisiana. He and three other men held in that facility together filed a writ of habeas corpus arguing their detention was unlawful. DeGravelles, who was appointed to the bench in 2014 by then-President Barack Obama, ordered their release Feb. 6, finding that ICE violated their constitutional rights by detaining them without a clear plan to deport them.
DeGravelles’ February order found ICE did not properly advise Mohammed his supervision order was being revoked when it arrested him last year. Despite this order, Liggins, who was recently promoted from ICE’s Baltimore office to oversee multiple East Coast field offices, testified he directed agents to arrest Mohammed on July 28. This re-arrest violated both the February release order and a subsequent March order.
DeGravelles said harsher sanctions would be warranted if his orders continued to go ignored. The contempt finding confirms that agency field directors cannot use judgment calls or policy disagreements to override judicial directives.
Why it matters
For practitioners, this ruling reinforces several critical habeas corpus and supervised release principles:
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ICE must follow judicial release orders. ICE needed to follow the typical process: reopening a case before an immigration judge before trying to send him to a third country. When a court orders release—especially on constitutional grounds—re-arrest without completing that process is not just factually wrong; it is contempt.
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Supervision order revocation requires proper notice. After ICE made unsuccessful attempts to find a third country willing to take him, agency officials released him on a supervision order, meaning it determined he was not a public safety threat. The fact that Mohammed was on supervision order status (not a deportation detainee) and was not properly advised of revocation before re-arrest was central to the judge’s findings.
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Contempt sanctions apply to senior officials. Liggins, who was recently promoted from ICE’s Baltimore office to oversee multiple East Coast field offices, was personally named and found culpable. This signals that the hierarchy does not insulate field directors from contempt liability for directing unlawful arrests.
Way forward
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Cite this ruling in habeas petitions defending clients against re-arrest after judicial release orders. It establishes binding district court precedent that ICE must follow release orders and cannot short-circuit the immigration court process.
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Document all judicial orders releasing your client or ordering specific procedures (e.g., reopening before an immigration judge). If ICE re-arrests, immediately file for contempt and cite deGravelles’s holding.
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Alert clients on supervision order status that revocation requires ICE to follow statutory notice procedures. If revocation occurs without proper notice, that fact strengthens a habeas or contempt claim.
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Monitor for pattern violations across cases. The court’s language about “harsher sanctions” suggests a judge’s patience is finite. Multiple violations by the same field office or official may trigger criminal contempt or other escalated remedies.
Disclaimer
This article is for informational purposes and does not constitute legal advice. Fola is a software company, not a law firm. Immigration law is complex and fact-specific; always consult a licensed immigration attorney about your case. Verify all claims against the primary source linked above. Federal court precedent and agency policy can change without notice.