A United States District Court judge in the Northern District of Texas has denied a motion for a temporary restraining order filed by Nigerian immigrant detainee Idoko Hillary Chibueze, who sought to block his deportation while his habeas corpus petition is pending.
Chibueze, a self-represented petitioner detained by U.S. Immigration and Customs Enforcement, filed the motion to prevent removal or deportation to Nigeria. He alleged that he would face persecution and possibly death if returned to his home country.
The detainee is currently held at the Prairieland Detention Center in Alvarado, Texas, having been transferred from the Bluebonnet Detention Center in Anson, Texas.
In his petition, Chibueze contended that his prolonged detention was unlawful due to the absence of a valid removal order or other legal justification. He sought declaratory and injunctive relief, including immediate release from custody.
However, in an order dated May 15, 2025, Judge James S. Hendrix ruled that Chibueze failed to meet the stringent legal standards required for the issuance of a TRO.
The judge noted that Chibueze did not verify his allegations under penalty of perjury, nor did he demonstrate efforts to notify the respondents or justify why notice should be excused. These procedural deficiencies alone warranted denial of the emergency relief.
Furthermore, the court found that Chibueze did not establish an immediate risk of irreparable harm.
Although he expressed fear of persecution if deported, he simultaneously stated in his petition that there was “no foreseeable likelihood of removal” at the present time. This contradiction undermined his claim of imminent danger requiring emergency intervention.
The judge stated that a temporary restraining order was an extraordinary remedy that requires a clear showing of irreparable injury, a substantial likelihood of success on the merits, a balance of harms favoring the plaintiff, and alignment with the public interest.
Since Chibueze failed to satisfy any of these elements, the motion was denied.
Chibueze also requested a hearing on the matter, which the court declined, citing the insufficiency of his motion and the absence of immediate threat.
The petitioner’s habeas corpus case remains pending. The court indicated that once Chibueze cures a filing-fee deficiency, the respondents will be required to file an answer to the petition.
