Y.A.P.A. v. Trump: An Alien Enemies Act Habeas Petition at Stewart, and the Process Owed Before CECOT
- Citation
- Y.A.P.A. v. Trump, No. 4:25-cv-144 (M.D. Ga. May 21, 2025)
- Court
- U.S. District Court for the Middle District of Georgia
- Decided
- May 21, 2025 (preliminary injunction)
- Statute
- Alien Enemies Act of 1798, 50 U.S.C. § 21; 28 U.S.C. § 2241; Fifth Amendment Due Process Clause
- Holding
- A Venezuelan detainee facing possible summary removal under the Alien Enemies Act was granted a preliminary injunction barring his AEA removal until the court could determine what process the Due Process Clause requires before the Act may be applied to him.
After the Supreme Court’s April 2025 ruling in Trump v. J.G.G., challenges to removal under the Alien Enemies Act had to be brought as individual habeas petitions in the district of confinement. The decision scattered the litigation across the country, into whichever districts held the detention facilities the government was using. Y.A.P.A. v. Trump, out of the Middle District of Georgia, is one of the petitions that followed — and one of the relatively few carried into a substantive ruling before the underlying controversy dissolved.
The petitioner at Stewart
Y.A.P.A. was a Venezuelan asylum-seeker held at the Stewart Detention Center in Lumpkin, Georgia. The government identified him as a “known associate” of Tren de Aragua — the designation that, under the March 2025 proclamation, exposed him to detention and possible removal under the 1798 wartime statute, including the prospect of transfer to El Salvador’s CECOT prison. He maintained the allegation was unsubstantiated. Fearing summary removal before he could be heard, he petitioned under § 2241.
The injunction
The court granted a preliminary injunction barring his removal under the Alien Enemies Act until it could determine what process the Due Process Clause requires before the Act is applied to an individual. The order reflected the central holding of J.G.G.: even where the government may proceed by habeas, it must give AEA detainees notice and a meaningful opportunity to seek relief in the proper venue before removal occurs. An allegation of gang association, contested and unadjudicated, was not a substitute for that process.
“Notice that comes too late to be acted upon is no notice at all; the writ exists precisely to make the opportunity to be heard real.”
How it ended, and why it still matters
The government did not ultimately pursue AEA removal against Y.A.P.A.; he elected to leave the United States, and the case was dismissed in September 2025. The preliminary injunction therefore stands as the operative ruling. Its significance is structural rather than precedential: it is a concrete example of how the post-J.G.G. habeas regime worked in practice in a circuit far from the District of Columbia, and of how district courts in the Eleventh Circuit and elsewhere insisted on real process before a centuries-old statute could deliver a person to a foreign prison. It belongs beside this archive’s entries on the District of Columbia, Colorado, and Texas AEA dockets as part of the geographic spread J.G.G. produced.
Filed under The Alien Enemies Act. Published May 21, 2025.