Unreported / Non-Citable
Background
Eugene Trifonov sought emergency relief against immigration officials, alleging unlawful enforcement actions. On December 22, 2025, Judge David O. Carter issued a Temporary Restraining Order requiring that any future enforcement actions against Trifonov after his release comply with the required procedures, finding he had made a sufficient showing under each of the four Winter v. Natural Resources Defense Council factors (likelihood of success on the merits, likelihood of irreparable harm, balance of equities, and public interest).
The court set a preliminary injunction hearing for January 5, 2026. Respondents filed an opposition on December 29, 2025; petitioner replied on December 31, 2025; and oral argument was held as scheduled.
The Court’s Holding
Judge Carter granted a preliminary injunction with the same restraint as the TRO: any future enforcement actions after Trifonov’s release must comply with the required procedures. Citing Lockheed Missile & Space Co. v. Hughes Aircraft Co. for the principle that the preliminary injunction standard is identical to the TRO standard, the court incorporated its prior Winter analysis from the TRO order rather than restating it.
The court added a clarifying note: it had previously observed that the absence of any travel documents suggested the petitioner was not going to be imminently removed (citing Hoac v. Becerra). And in the event such travel documents materialized, Trifonov would still be entitled to an opportunity to be heard before any enforcement action was taken.
Key Takeaways
- Where a court has already granted a TRO under Winter, it may grant a preliminary injunction by incorporating the prior Winter analysis without further restating each factor — the standards are legally identical.
- Immigration enforcement actions against released parolees or persons granted release under court order require compliance with constitutional and statutory procedural protections.
- The absence of travel documents is meaningful evidence that imminent removal is not occurring; courts can rely on that evidence in finding likelihood of irreparable harm.
- Even if travel documents are later obtained, the noncitizen retains a procedural right to be heard before further enforcement.
- Preliminary injunctions in this context restrict the government’s enforcement action without finally adjudicating immigration status — they preserve the status quo while the underlying habeas action proceeds.
Why It Matters
This is a brief but useful confirmation order that follows the now-standard pattern in C.D. Cal. immigration enforcement cases: TRO based on a Winter analysis, then a preliminary injunction at the next scheduled hearing. The procedural simplicity of incorporating a prior Winter analysis underscores how settled this framework has become in the District.
For immigration counsel, this opinion confirms that emergency relief once granted will typically convert into a preliminary injunction at the standard hearing — the burden does not reset. For the government, the order signals that procedural-compliance-based injunctions are difficult to displace once entered.