Nguikoh

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA

MONROE DIVISION

RINNETTE NGUIKOH #A221-075-224 CASE NO. 3:26-CV-00567 SEC P

VERSUS JUDGE JAMES D. CAIN, JR.

FIELD OFFICE DIRECTOR ET AL MAGISTRATE JUDGE LEBLANC

MEMORANDUM ORDER

Before the court is a Motion for Emergency Release [doc. 3] filed by immigration

detainee Rinnette Nguikoh, in connection with her pending petition for writ of habeas

corpus. See doc. 6. Ms. Nguikoh, a native of Cameroon, argues that ICE revoked her parole

without providing her explanation or a meaningful hearing. Id. at 2. She asks this court to

release her pending a resolution of her petition, citing her pending appeal of the removal

order and her compliance with the terms of supervision during her parole. Doc. 3. The court

construes this request as a motion for temporary restraining order.

An applicant for a temporary restraining order (“TRO”) or preliminary injunction

must demonstrate each of the following: (1) a substantial likelihood that his cause will

succeed on the merits, (2) a substantial threat of irreparable injury if the injunction is not

granted, (3) that the threatened injury outweighs the threatened harm that the injunction

might do to the opposing party, and (4) that granting the injunction will not disserve the

public interest. Misquitta v. Warden Pine Prairie ICE Processing Ctr., 353 F.Supp.3d 518,

521 (W.D. La. 2018) (citing Piedmont Heights Civic Club, Inc. v. Moreland, 637 F.2d 430

(5th Cir. 1981)). The decision of whether to grant or deny a TRO lies in the district court's

discretion. Moore v. Brown, 868 F.3d 398, 402 (5th Cir. 2017). Courts should deny such

motions more often than not. Albright v. City of New Orleans, 46 F.Supp.2d 523, 532 (E.D.

La. 1999) (explaining that temporary restraining orders are “extraordinary relief and rarely

issued.”); see also Suburban Propane, L.P. v. D & S GCTX LLC, 2025 WL 2429087, at *2

(W.D. Tex. 2025) (holding that the extraordinary relief under Rule 65 must be

“unequivocally show[n].”); Anderson v. Jackson, 556 F.3d 351, 355-56 (5th Cir. 2009)

(“Only under ‘extraordinary circumstances’ will this court reverse the denial of a

preliminary injunction.”’).

The petitioner’s request for immediate release cites no threat of imminent harm.

Instead, she merely seeks to accelerate her request for the ultimate relief requested under

her habeas petition. Courts should not allow petitioners to skip the line on habeas review

by dressing their petitions as TRO’s. See Rodriguez v. Lyons, 2025 WL 3553742, at *1

(W.D. La. Dec. 8, 2025) (denying a “motion to decide my habeas petition now.’’); Lindell

v. United States, 82 F.Ath 614, 618 (8th Cir. 2023) (“[T]he purpose of injunctive relief is to

preserve the status quo; it is not to give the movant the ultimate relief he seeks.”). The

petitioner’s alternative request for a bond hearing is unavailing under controlling authority

in this circuit. Buenrostro-Mendez v. Bondi, 166 F.4th 494 (Sth Cir. 2026). Accordingly, IT

IS ORDERED that the Motion [doc. 3] be DENIED. The matter is referred to the

magistrate judge for expedited review.

THUS DONE ANB-STGNED in Chambers on the 23gefday-of March, 2026.

Vx OA?

7 JAMES D. CAIN. 2

UNITED STATES DISTRICT JUDGE

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