Mahdawi v. Trump: A Naturalization Interview Becomes a Habeas Case
- Citation
- Mahdawi v. Trump, No. 2:25-cv-00389 (D. Vt.) (Crawford, J.)
- Court
- U.S. District Court for the District of Vermont
- Judge
- Hon. Geoffrey W. Crawford
- Statute
- 28 U.S.C. § 2241; First and Fifth Amendments; 8 U.S.C. § 1226(a)
- Holding
- Habeas granted; petitioner released on bail; subsequent IJ termination of removal proceedings; Second Circuit appeal pending (argued Sept. 30, 2025 with Ozturk).
Mohsen Mahdawi is a Columbia University student and a lawful permanent resident. He was raised in a West Bank refugee camp before arriving in the United States. On April 14, 2025, he attended a naturalization interview in Vermont. ICE arrested him as he left the building. The use of a naturalization interview — an applicant-initiated, civil, expressly non-adversarial process — as the venue for an enforcement arrest was unprecedented in modern immigration practice.
The release order
On April 30, 2025, Judge Geoffrey Crawford of the District of Vermont granted habeas and ordered Mahdawi’s release on bail. The opinion contains one of the most pointed judicial statements in the 2025 student-detention docket. “Legal residents not charged with crimes or misconduct,” the court wrote, “are being arrested and threatened with deportation for stating their views on the political issues of the day.” The court found Mahdawi’s First Amendment claims meritorious on their face and the government’s evidence supporting continued detention insufficient.
“Legal residents not charged with crimes or misconduct are being arrested and threatened with deportation for stating their views on the political issues of the day.”
The IJ termination
In the months following the release order, the immigration judge presiding over Mahdawi’s removal proceedings terminated those proceedings. The IJ’s decision is not extensively reported, but the result effectively mooted the underlying removal threat that had given rise to the habeas case. Mahdawi’s naturalization application has, as of this writing, not yet been adjudicated.
The Second Circuit appeal
The government appealed Judge Crawford’s release order. Oral argument before the Second Circuit was held on September 30, 2025, paired with the appeal in Ozturk v. Trump. The principal appellate questions are the same in both cases: whether the district court had habeas jurisdiction notwithstanding § 1252(b)(9), and whether the substantive First Amendment ruling was correct. A decision was pending as of this writing.
Significance
The case’s most disturbing feature — the use of a naturalization interview as an arrest venue — is also its most replicable threat. If the practice spreads, applicants will face a stark choice: pursue naturalization and risk arrest, or remain in lawful permanent resident status indefinitely. The chilling effect on naturalization applications by noncitizens with controversial speech histories is, by design or otherwise, substantial.
For habeas practice, the case complements Ozturk in establishing the District of Vermont as a forum unusually willing to resist ICE jurisdiction-manipulation. The Second Circuit’s eventual ruling on the paired Ozturk/Mahdawi appeals will resolve how durable that district-court resistance is. As of this writing, the practical relief obtained by Mahdawi has held: he is at liberty, removal proceedings have been terminated, and the naturalization application remains pending.
Filed under First Amendment Detentions. Published April 30, 2025.