Edmundo M. Campos v. Immigr. & Naturalization Serv., 62 F.3d 311 (9th Cir. 1995). · Go Syfert
Edmundo M. Campos v. Immigr. & Naturalization Serv., 62 F.3d 311 (9th Cir. 1995). Cases Citing This Book View Copy Cite
“he bare detainer letter alone does not sufficiently place an alien in ins custody 13 to make habeas corpus available.”
63 citation events (40 in the last 25 years) across 25 distinct courts.
Strongest positive: Dat v. United States Immigration and Customs Enforcement (wawd, 2020-01-03)
Treatment trajectory · 1995 → 2026 · click a year to view as-of
1995 2010 2026
Top citers, strongest first. 45 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Dat v. United States Immigration and Customs Enforcement
W.D. Wash. · 2020 · quote attribution · 1 verbatim quote · confidence high
the bare detainer letter alone 2 does not sufficiently place in ins custody to make habeas corpus 3 available
discussed Cited as authority (verbatim quote) Tinh v. Howe
D. Nev. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
he bare detainer letter alone does not sufficiently place an alien in ins custody 13 to make habeas corpus available.
discussed Cited as authority (rule) Loeung v. Arnold
W.D. Wash. · 2025 · confidence medium
Because an immigration detainer does not mean an individual is—or certainly will be—subject to a final order of removal, the Ninth Circuit has 8 explained, “the bare detainer letter alone does not sufficiently place [a noncitizen] in…custody to make habeas corpus available.” Garcia v. Taylor, 40 F.3d 299 , 303 9 (9th Cir. 1994) superseded by statute on other grounds as stated in Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir. 1995). 10 11 Dkt. 5 at 3–4. 12 Because Petitioner, a state prisoner, is attempting to challenge his bare detainer letter, the 13 Court lacks jurisdiction to hear…
cited Cited as authority (rule) Forbes v. Warden, FCI McDowell
S.D.W. Va · 2025 · confidence medium
An immigration detainer “does not sufficiently place an alien in ICE custody to make habeas corpus available.” Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) (cleaned up).
cited Cited as authority (rule) (HC) Kifah v. Sheriff
E.D. Cal. · 2025 · confidence medium
Cal. 2010) (“A detainer letter or ‘hold’ are insufficient to place 11 petitioner in federal custody for habeas corpus purposes”); Campos v. INS, 62 F.3d 311, 313 (9th 12 Cir. 1995) (same).
discussed Cited as authority (rule) Bailey v. Borda
N.D. Cal. · 2024 · confidence medium
And unfortunately for petitioner, 20 it is well established that an immigration detainer “does not sufficiently place an alien in [ICE] 21 custody to make habeas corpus available.” Garcia v. Taylor, 40 F.3d 299, 303 (9th Cir. 1994), 22 superseded by statute on other grounds as stated in, Campos v. INS, 62 F.3d 311,314 (9th Cir. 23 1995).
discussed Cited as authority (rule) Reding-Lorenzana v. Bludworth
D. Mont. · 2024 · confidence medium
The Ninth Circuit has determined that “a bare detainer alone does not sufficiently place an alien in INS custody to make habeas corpus available.” Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) (quoting Garcia v. Taylor, 40 F.3d 299, 303 (9th Cir. 1994); see also Zolicoffer v. United States Dep’t of Justice, 315 F.3d 538, 540 (5th Cir. 2003) (collecting cases, finding that absent an order of removal “prisoners are not ‘in custody’ for purposes of 28 U.S.C. § 2241 simply because the INS has lodged a detainer against them.”).
discussed Cited as authority (rule) (HC) Tieu v. USA
E.D. Cal. · 2024 · confidence medium
The Ninth Circuit has held that a “bare 8 detainer letter alone does not sufficiently place [a petitioner] in INS[1] custody to make habeas 9 corpus available.” Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) (quoting Garcia v. Taylor, 10 40 F.3d 299, 303 (9th Cir. 1994)). 11 Petitioner argues that he “is unquestionably in the technical custody” of ICE as a result of 12 the detainer.
cited Cited as authority (rule) Zheng v. Mayorkas
N.D. Cal. · 2024 · confidence medium
Cal. May 26, 2016) (citing Campos v. I.N.S., 62 F.3d 311, 313-14 (9th 22 Cir. 1995)); see also Yan, 2023 U.S. Dist.
discussed Cited as authority (rule) Gaona Murillo v. Derr
D. Haw. · 2022 · confidence medium
To the extent Gaona Murillo is attempting to challenge an immigration detainer, ECF No. 1 at 2, it is well established that a “bare detainer letter alone does not sufficiently place an alien in [DHS] custody to make habeas corpus available.” Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir. 1995); Martinez v. Mukasey, 263 F. App’x 648, 649 (9th Cir. 2008) (“Habeas corpus is not available to challenge the detainer.”).
discussed Cited as authority (rule) Lopez v. Derr
D. Haw. · 2022 · confidence medium
Regardless, a “bare detainer letter alone does not sufficiently place an alien in [DHS] custody to make habeas corpus available.” Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir. 1995); Martinez v. Mukasey, 263 F. App’x 648, 649 (9th Cir. 2008) (“Habeas corpus is not available to challenge the detainer.”).
discussed Cited as authority (rule) D Angelo Nunez v. United States (2×) also: Cited "see"
C.D. Cal. · 2021 · confidence medium
Accordingly, the Ninth Circuit has held that a “bare detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available.’” Campos v. LN.S., 62 F.3d 311, 314 (9th Cir. 1995) (quoting Garcia v. Taylor, 40 F.3d 299, 303 (9th Cir. 1994)); see also United States v. Female Juvenile, A.F.S., 377 F.3d 27, 35 (1st Cir. 2004) (“[A]n INS detainer ts not, standing alone, an order of custody.
discussed Cited as authority (rule) (HC) Mousa v. Immigration & Customs Enforcement
E.D. Cal. · 2020 · confidence medium
At the time of filing, Petitioner was in the custody of the California Department of 10 Corrections and Rehabilitation, and the Ninth Circuit has held that a “bare detainer letter alone 11 does not sufficiently place an alien in INS custody to make habeas corpus available.” Garcia v. 12 Taylor, 40 F.3d 299, 303 (9th Cir. 1994), superseded by statute on other grounds as stated in 13 Campos v. Immigration & Naturalization Serv., 62 F.3d 311, 314 (9th Cir. 1995).
discussed Cited as authority (rule) (HC) Mousa v. Immigration & Customs Enforcement
E.D. Cal. · 2019 · confidence medium
The Ninth Circuit has held that a “bare detainer letter alone does not 7 sufficiently place an alien in INS4 custody to make habeas corpus available.” Garcia v. Taylor, 8 40 F.3d 299, 303 (9th Cir. 1994), superseded by statute on other grounds as stated in Campos v. 9 Immigration and Naturalization Serv., 62 F.3d 311, 314 (9th Cir. 1995).
cited Cited as authority (rule) Camarena v. Slade
9th Cir. · 2004 · confidence medium
Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
cited Cited as authority (rule) Tran v. Campbell
9th Cir. · 2002 · confidence medium
Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995) (deciding that an INS detainer letter alone does not sufficiently place a defendant in INS custody to make habeas corpus available).
cited Cited as authority (rule) Barapind v. Reno
E.D. Cal. · 1999 · confidence medium
Ardestani v. INS, 502 U.S. 129, 133 , 112 S.Ct. 515 , 116 L.Ed.2d 496 (1991); Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
discussed Cited as authority (rule) Independence Mining Co. v. Babbitt
9th Cir. · 1997 · confidence medium
Oregon Natural Resources Council v. Harrell, 52 F.3d 1499, 1508 (9th Cir.1995) (listing elements of mandamus test); Garcia v. Taylor, 40 F.3d 299, 301 (9th Cir.1994), superseded by statute on other grounds as stated in, Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir.1995); Fallini v. Hodel, 783 F.2d 1343, 1345 (9th Cir.1986).
discussed Cited as authority (rule) 97 Cal. Daily Op. Serv. 516, 97 Daily Journal D.A.R. 829 Independence Mining Company, Inc. v. Bruce Babbitt, Secretary of the Interior United States Department of the Interior and the Bureau of Land Management
9th Cir. · 1997 · confidence medium
Oregon Natural Resources Council v. Harrell, 52 F.3d 1499, 1508 (9th Cir.1995) (listing elements of mandamus test); Garcia v. Taylor, 40 F.3d 299, 301 (9th Cir.1994), superseded by statute on other grounds as stated in, Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir.1995); Fallini v. Hodel, 783 F.2d 1343, 1345 (9th Cir.1986).
examined Cited as authority (rule) United States v. Lopez (3×) also: Cited "see", Cited "see, e.g."
E.D. Va. · 1996 · confidence medium
After INTCA, the Ninth Circuit correctly observed that "the target of [INTCA § 225] thus must have been our Ninth Circuit law allowing mandamus relief." Campos, 62 F.3d at 314.
discussed Cited as authority (rule) Moreno-Suarez v. Reno
W.D. La. · 1996 · confidence medium
In Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995), the Ninth Circuit recognized that its holding in Silveyra had been legislatively overruled and stated that the Silveyra ruling was obviously the target of § 225 of INTCA.
cited Cited as authority (rule) Jesus Gutierrez-Tavares v. Immigration and Naturalization Service
9th Cir. · 1996 · confidence medium
Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir.1995) and Urbina-Maurico v. I.N.S., 989 F.2d 1085 (9th Cir.1993). 21 Nor does the Constitution offer a remedy.
discussed Cited as authority (rule) Luis Arango-Alvarez v. Immigration and Naturalization Service
6th Cir. · 1996 · confidence medium
The contrary authority upon which Arango-Alavarez relies, Garcia v. Taylor, 40 F.3d 299, 301 (9th Cir.1994), has been overruled by statute, as stated in Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
discussed Cited as authority (rule) Roberto M. Cervantes v. A.D. Moyer, District Director of the Immigration and Naturalization Service, R.E. Holt, Warden (2×) also: Cited "see"
7th Cir. · 1996 · confidence medium
Indeed, Aguirre was published expressly "to establish circuit-wide precedent that section 1252(i) does not create a private right of action." Aguirre, 930 F.2d at 1293 . 1 Furthermore, in 1994, Congress enacted legislation "to clarify for our benefit that section 1252(i) does not create an obligation on the part of the government toward individual incarcerated aliens and that such aliens lack standing to sue for any relief under section 1252 because they are outside the 'zone of interests' of the statute." Campos, 62 F.3d at 314 (construing Immigration Nationality Technical Corrections Act of …
cited Cited as authority (rule) UNITED STATES of America, Plaintiff-Appellee, v. John WASHINGTON, Defendant-Appellant
9th Cir. · 1995 · confidence medium
The Cretacci majority observed that a defendant's claim of ownership of property that was subject to forfeiture may not later be used to prove the defendant's guilt. 62 F.3d at 311; but see id.
cited Cited "see" (HC) Hurtadodominguez v. United States
E.D. Cal. · 2025 · signal: see · confidence high
See generally Campos v. I.N.S., 62 F.3d 311 (9th Cir. 1995).
cited Cited "see" Fang Yan v. Dir LA Asylum Ofc
C.D. Cal. · 2023 · signal: see · confidence high
See Campos v. I.N.S., 62 F.3d 311 , 6 313–14 (9th Cir. 1995); see also, e.g., Pesantez v. Johnson, No. 15 CIV. 1155 (BMC), 7 2015 WL 5475655 , at *2 (E.D.N.Y.
discussed Cited "see" Xayamonty v. United States
D. Nev. · 2023 · signal: see · confidence high
See Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir. 1995) (citation omitted). 5 Accordingly, the Magistrate Judge properly found that the Court “cannot interfere in that 6 process before it actually begins.” (R&R 3:8–9). 7 In sum, the Court, upon conducting a de novo review of the Magistrate Judge’s findings, 8 determine that the recommendation and findings are proper.
discussed Cited "see" (HC) Mousa v. Immigration & Customs Enforcement
E.D. Cal. · 2019 · signal: see · confidence high
See Garcia v. Taylor, 40 F.3d 299, 303 (9th Cir. 1994) (holding that a bare 25 detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus 26 available”), superseded by statute on other grounds as stated in Campos v. Immigration and 27 Naturalization Serv., 62 F.3d 311, 314 (9th Cir. 1995); Zolicoffer v. U.S. Dep’t of Justice, 315 F.3d 538, 540 (5th Cir. 2003) (“Most of the circuit courts that have considered the question have 1 | held that [an immigration] detainer does not place a prisoner in ‘custody’ for purposes of habeas 2 | proceedings.”).…
discussed Cited "see" Voces De La Frontera, Inc. v. Clarke (2×)
Wis. Ct. App. · 2016 · signal: see · confidence high
See Campos v. Immigration and Naturalization Serv., 62 F.3d 311, 313-14 (9th Cir. 1995). " '[T]he bare detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available.' " Id. at 314 (citation omitted). "[A]n INS detainer is not, standing alone, an order of custody.
discussed Cited "see" Mendia v. Garcia
N.D. Cal. · 2016 · signal: see · confidence high
See Garcia v. Taylor, 40 F.3d 299, 303 (9th Cir.1994) (“We now agree with the circuits which have expressed the opinion that the bare [INS] detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available.”), superseded by statute on other grounds as stated in Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir.1995).
cited Cited "see" In Re: Gonzalo Mota-Rivera v.
3rd Cir. · 2011 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 313-14 (9th Cir.1995).
cited Cited "see" Mitchell v. Mukasey
9th Cir. · 2008 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
cited Cited "see" Martinez v. Mukasey
9th Cir. · 2008 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
discussed Cited "see" Zolicoffer v. DOJ
5th Cir. · 2003 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995)(detainer letter alone does not sufficiently place an alien in INS custody for habeas purposes); Galaviz-Medina v. Wooten, 27 F.3d 487, 493 (10th Cir.1994)(because prisoner had a detainer plus a final order of deportation against him, he was in INS "custody" for habeas purposes); Orozco v. INS, 911 F.2d 539, 541 (11th Cir.1990)(filing of detainer, standing alone, did not cause the prisoner to come within INS custody); Mohammed v. Sullivan, 866 F.2d 258, 260 (8th Cir.1989)(filing of an INS detainer with prison officials does not constitute the r…
discussed Cited "see" Zolicoffer v. United States Department of Justice
5th Cir. · 2003 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995)(detainer letter alone does not sufficiently place an alien in INS custody for habeas purposes); Galaviz-Medina v. Wooten, 27 F.3d 487, 493 (10th Cir.1994)(because prisoner had a detainer plus a final order of deportation against him, he was in INS “custody” for habeas purposes); Orozco v. INS, 911 F.2d 539, 541 (11th Cir.1990)(filing of detainer, standing alone, did not cause the prisoner to come within INS custody); Mohammed v. Sullivan, 866 F.2d 258, 260 (8th Cir.1989)(filing of an INS detainer with prison officials does not constitute t…
cited Cited "see" Naddi v. Lamarque
9th Cir. · 2001 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995) (holding that the INS’s detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available).
cited Cited "see" Christopher I. Onyejekwe v. Immigration and Naturalization Service
6th Cir. · 1996 · signal: see · confidence high
See Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995).
discussed Cited "see, e.g." Tchouala v. Swaney
S.D. Tex. · 2025 · signal: see also · confidence medium
See Zolicoffer v. United States Dep’t of Just., 315 F.3d 538, 541 (5th Cir. 2003); see also Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) (a detainer letter alone does not place a prisoner in ICE custody for habeas purposes); Galviz-Medina v. Wooten, 27 F.3d 487, 493 (10th Cir. 1994) (a detainer, without more, is insufficient to put a prisoner in ICE custody).
discussed Cited "see, e.g." Alberto-Toledo v. Pulver
D. Or. · 2021 · signal: see, e.g. · confidence medium
See, e.g., Campos v. I.N.S., 62 F.3d 311, 314 (9th Cir. 1995) (affirming that a “bare detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available”); Sayadeth v. Apker, 2016 WL 8731393 , at *2-3 (E.D.
discussed Cited "see, e.g." Tapia-Garcia v. United States
S.D.N.Y. · 1999 · signal: see, e.g. · confidence medium
See, e.g., Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995); Hernandez-Avalos v. INS, 50 F.3d 842, 844 (10th Cir.), cert. denied, 516 U.S. 826 , 116 S.Ct. 92 , 133 L.Ed.2d 49 (1995); Pedraza v. INS, No. C97-0690, 1997 WL 118261 at *1 & n. 1 (N.D.Cal.
discussed Cited "see, e.g." Renteria-Piedrahita v. Thompson
4th Cir. · 1996 · signal: see also · confidence medium
No. 103-416, Sec. 225 , 108 Stat. 4305 ; see also Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995) (overruling prior Ninth Circuit cases); Hernandez-Avalos, 50 F.3d 842, 844 (10th Cir.1995), cert. denied, 64 U.S.L.W. 3241 (U.S.1995). 3 Therefore, we affirm the district court order.
discussed Cited "see, e.g." Renteria-Piedrathita v. Thompson
4th Cir. · 1996 · signal: see also · confidence medium
No. 103-416, § 225 , 108 Stat. 4305 ; see also Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) (overruling prior Ninth Circuit cases); Hernandez-Avalos, 50 F.3d 842, 844 (10th Cir. 1995), cert. denied, 64 U.S.L.W. 3241 (U.S. 1995).
cited Cited "see, e.g." Marmolejos v. INS
1st Cir. · 1995 · signal: see also · confidence medium
See also Campos v. INS, 62 F.3d 311, 314 (9th Cir.1995) (Sec. 225 makes clear that Sec. 242(i) does not place any obligations on the government).
discussed Cited "see, e.g." Marmolejos v. INS
1st Cir. · 1995 · signal: see also · confidence medium
See also ___ ____ Campos v. INS, 62 F.3d 311, 314 (9th Cir. 1995) ( 225 makes ______ ___ clear that 242(i) does not place any obligations on the government).
Retrieving the full opinion text from the archive…
Edmundo M. CAMPOS, Petitioner-Appellant,
v.
IMMIGRATION AND NATURALIZATION SERVICE, Et Al., Respondents-Appellees
94-15361.
Court of Appeals for the Ninth Circuit.
Aug 4, 1995.
62 F.3d 311
Katherin Sears, Joel S. Sanders, Gibson, Dunn & Crutcher, San Francisco, CA, for petitioner-appellant., Donald E. Keener, Office of Immigration Litigation, U.S. Dept, of Justice, Washington, D.C., and Patricia A. Duggan, Asst. U.S. Atty., San Francisco, CA, for respondents-appellees.
Schroeder, Beezer, Thompson.
Cited by 53 opinions  |  Published
Pinpoint authority: bottom 54%
SCHROEDER, Circuit Judge:

Federal prisoner and alien Edmundo Campos appeals the district court’s summary judgment in favor of the Immigration and Naturalization Service (“INS”) in Campos’ mandamus action seeking an expedited deportation hearing pursuant to 8 U.S.C. § 1252(i). We must decide whether Congress in 1994 legislatively overruled the law of this circuit that permitted an incarcerated alien to seek such mandamus relief. See, e.g., Silveyra v. Moschorack, 989 F.2d 1012, 1014 n. 1 (9th Cir.1993). To assist our inquiry, we appointed counsel from our court’s pro bono representation project. We conclude that in passing section 225 of the Immigration and Nationality Technical Corrections Act of 1994, Pub.L. No. 103-416 (“INTCA”), Congress has foreclosed mandamus actions under section 1252(i). We affirm the district court’s judgment denying relief.

Petitioner-appellant Edmundo Campos was born in Lima, Peru in 1953 and entered the United States as a legal permanent resident alien in 1977. Campos was sentenced in 1989 to 15 years’ federal imprisonment and a life term of supervised release for possession and conspiracy to possess cocaine with intent to distribute. Convictions for these crimes subject Campos to the possibility of deportation upon his release from prison. See 8 U.S.C. § 1252. His targeted good conduct release date is presently April 12, 1996.

[*313] Although Campos began serving his sentence in February of 1989, the INS took no action until June of 1992, when it filed a detainer with the Bureau of Prisons at the Federal Correctional Institution at Oakdale, Louisiana. [1] The detainer directs the Bureau of Prisons to ensure that Campos is transferred to Oakdale six months before the end of his sentence.

In 1993 Campos filed this action in district court seeking relief by means of a writ of habeas corpus pursuant to 28 U.S.C. § 2241, a claim under the Administrative Procedures Act, 5 U.S.C. §§ 701-706 (“APA”) or, alternatively, a mandamus claim requesting the court to compel the INS to hold an immediate deportation hearing pursuant to 8 U.S.C. § 1252(i). 8 U.S.C. § 1252(f) provides:

In the case of an alien who is convicted of an offense which makes the alien subject to deportation, the Attorney General shall begin any deportation proceeding as expeditiously as possible after the date of the conviction.

In its order to show cause, the district court denied Campos’ claims for habeas and APA relief but acknowledged that Campos had presented a cognizable claim for mandamus. Ultimately, the district court granted summary judgment in favor of the INS, denying Campos mandamus relief on several grounds.

One of the reasons the district court granted summary judgment for the INS was the Service’s representation that it would provide Campos with a deportation hearing before the completion of his sentence. As counsel for Campos accurately pointed out in oral argument of this appeal nearly a year and one-half later, however, because the INS has not yet instituted deportation proceedings, it is highly unlikely Campos will have a hearing and exhaust available appellate remedies before his targeted release date. He thus faces the likelihood that any challenge he makes to deportation will be at the risk of further detention beyond his criminal sentence.

Similar delays and seemingly unnecessary, prolonged incarceration prompted our decisions in a line of eases finding standing under the Mandamus Act [2] for incarcerated aliens to seek immediate deportation hearings. See Silveyra v. Moschorack, 989 F.2d 1012, 1014 n. 1 (9th Cir.1993); cf. Soler v. Scott, 942 F.2d 597, 605 (9th Cir.1991), vacated as moot sub nom. Sivley v. Soler, — U.S. -, 113 S.Ct. 454, 121 L.Ed.2d 364 (1992), cited with approval in Silveyra, 989 F.2d at 1014 n. 2 (finding rationale of Soler “sound”); Garcia v. Taylor, 40 F.3d 299, 301 (9th Cir.1994) (recognizing it is “settled” that “prisoner aliens who seek mandamus to force the INS to start deportation proceedings do have standing”). In Silveyra, we held that 8 U.S.C. § 1252(i) created a duty to incarcerated aliens because the plaintiff prisoner fell within the “zone of interests” protected by the underlying statute. See Silveyra, 989 F.2d at 1014 n. 1. The Fifth Circuit reached an opposite conclusion in Giddings v. Chandler, 979 F.2d 1104 (5th Cir.1992), holding that an incarcerated alien lacked standing to invoke the Mandamus Act to compel the institution of deportation proceedings. Id. at 1108-1110.

In 1994, Congress passed the Immigration and Nationality Technical Corrections Act of 1994, Pub.L. No. 103 — 416, 108 Stat. 4305 (“INTCA”). Section 225 of the Act provides that:

[no] amendment made by this Act and nothing in § 242(i) of the Immigration and Nationality Act (8 U.S.C. § 1252(f)) shall be construed to create any substantive or procedural right or benefit that is legally enforceable by any party against the United States or its agencies or officers or any other person.

INTCA, § 225.

In this appeal the INS contends that the INTCA overrules our prior authority and[*314] denies Campos standing, to seek mandamus relief. The mandamus suits that we permitted in Soler, Silveyra, and Garcia.were actions by incarcerated aliens brought to obtain the procedural benefit of an accelerated deportation hearing. Now, however, section 225 of the INTCA forecloses such relief as it expressly bars actions for “substantive or procedural” relief under section 1252(i).

Campos nevertheless contends that section 225 of the INTCA was only intended to eliminate judicial relief founded on a private right of action; therefore, he argues, the INTCA does not bar mandamus standing. This position is not tenable because prior to the enactment of INTCA, no circuit had recognized a private right of action under section 1252. The decisions, including one by our own court, unanimously held that no private cause of action exists under the statute. [3]

The intended target of section 225 thus must have been our Ninth Circuit law allowing mandamus relief. In Silveyra this court recognized that section 1252(i) primarily was enacted to avoid the high costs of extended incarceration:

[ajlthough 8 U.S.C. § 1252(i) was apparently enacted for the benefit of taxpayers rather than incarcerated aliens, [citation omitted], Silveyra’s suit advances the stated Congressional purpose of reducing prison overcrowding caused by INS delay, and thus Silveyra falls within the ‘zone of interests’ protected by § 1252(f).

Silveyra, 989 F.2d at 1014 n. 1. Congress took the opportunity in section 225 of the INTCA to clarify for our benefit that section 1252(f) does not create an obligation on the part of the government toward individual incarcerated aliens and that such aliens lack standing to sue for any relief under section 1252 because they are outside the “zone of interests” of the statute. The scant legislative history of section 225 supports our reading of the section’s language. See 140 Conf. Rec. H11292 (daily ed. Oct. 7, 1994) (statement of Rep. Brooks) (section 225 “clarifies that ... the requirement in current law of speedy deportation for criminal aliens do[es] not create enforcement rights against the United States.”). By enacting section 225, Congress made clear that the sole purposes of section 1252(f) are economic, not humanitarian.

The result we reach is consistent with that reached by the Tenth Circuit in the only other post-INTCA case to have reached the appellate courts. See Hernandez-Avalos v. INS, 50 F.3d 842, 844 (10th Cir.1995), cert. denied, - U.S. -, 116 S.Ct. 92, — L.Ed.2d - (1995).

Appellant’s appointed counsel also contests the district court’s dismissal of petitioner’s habeas and APA claims. We affirm the denial of relief on these grounds as well. This court has recently concluded that “the bare detainer letter alone does not sufficiently place an alien in INS custody to make habeas corpus available.” Garcia, 40 F.3d at 303. Additionally, our law is clear that APA claims are not viable in the section 1252(i) context. See Silveyra, 989 F.2d at 1015 (“no claim under the [APA] because ‘immigration proceedings ... are not governed by the APA.’ ”) (citing Ardestani v. INS, 502 U.S. 129, 133, 112 S.Ct. 515, 518, 116 L.Ed.2d 496 (1991)); INTCA, § 225 (no judicially enforceable benefits or rights under section 1252(i)).

AFFIRMED.

1

. Under the Criminal Alien Institutional Hearing Program ("IHP"), the Executive Office for Immigration Review attempts to facilitate expeditious hearings for inmates in federal custody by centralizing disbursed inmate populations at designated Bureau of Prisons facilities. One such federal facility is the Oakdale, Louisiana Federal Correctional Institution.

2

. The Mandamus Act, 28 U.S.C. § 1361, provides:

The district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff.
3

. See Urbina-Mauricio v. INS, 989 F.2d 1085 (9th Cir.1993) (no private right of action under § 1252(i)); Aguirre v. Meese, 930 F.2d 1292, 1293 (7th Cir.1991) (same); Prieto v. Gluch, 913 F.2d 1159, 1166 (6th Cir.1990) (same), cert. denied, 498 U.S. 1092, 111 S.Ct. 976, 112 L.Ed.2d 1061 (1991); Orozco v. INS, 911 F.2d 539, 541 (11th Cir.1990) (same); cf. Gonzalez v. INS, 867 F.2d 1108, 1109-10 (8th Cir.1989) (no private right of action under § 1252(f), therefore mandamus not available).