Product Documentation
Workflow-driven immigration case management for detained individuals.
Habeas Rabbit is a structured workflow system for immigration attorneys handling detention- and court-based cases. It encodes the deterministic legal logic — circuit respondent rules, Zadvydas threshold math, POCR deadlines — that practitioners currently track by hand, and generates the documents needed for district court and EOIR filings
The Problem
Immigration detention cases generate overlapping deadlines and circuit-specific rules that practitioners track manually.
A single detained client may have:
- A habeas petition filed in federal court
- A bond hearing before an immigration judge
- A post-order custody review pending with ICE
- A pending FOIA request with USCIS
— all running concurrently with different deadlines, different respondents, and different legal standards and formats.
The rules that govern each of these proceedings are specific, well-established — and prone to error when they're applied manually under growing caseload pressure.
The Approach
A matter-first case management system with encoded legal logic and guided workflows.
Each client intake creates a unified matter that can contain multiple concurrent proceedings. Habeas Rabbit applies deterministic logic to each — no approximations, no AI-generated guesses — and surfaces the right respondents, the right deadlines, and the right documents at each step.
The workflow is guided, not open-ended. Practitioners move through structured intake steps that enforce completeness before document generation. The result is a filing package built on validated data the practitioner reviewed and confirmed.
Core Workflows
Four guided workflows. One unified matter record.
Client Matter
Unified Case Record
One intake creates a shared record — detention history, client data, and A-Number — available to all concurrent proceedings without re-entry.
28 U.S.C. § 2241
Habeas Corpus
5-step intake
4 court documents
EOIR · Immigration Court
Bond Hearing
6-step intake
3 motion documents
ICE Post-Order Custody
POCR Request
Correction workflow
2 request documents
ICE · USCIS · CBP · EOIR · DHS
FOIA Requests
5 agencies
5 request letters
Step 1 of 5
Habeas Corpus Petitions
28 U.S.C. § 2241
The core workflow. Guided intake across five steps — client and detention data, facility history, respondent selection, claim drafting, and document generation — producing a complete district court filing package.
- Circuit-specific respondent determination applied automatically based on detention facility
- Detention days aggregated across facility transfers against the 180-dayZadvydas threshold
- Generates petition, civil cover sheet (JS-44), summons (AO-440), and certificate of service — all in a single package
Step 1 of 6
Bond Hearings
EOIR · Immigration Court
Six-step workflow for bond hearings before immigration judges and BIA appeals. Structures hearing history, evidence organization, and legal argument scaffolding with applicable case citations.
- Bond motion and supporting brief generation with embedded legal standards
- BIA appeal workflow for bond hearing denial
- Evidence checklist and hearing history tracking across multiple bond hearings
Post-Order
POCR Requests
ICE · Post-Order Custody Review
Post-Order Custody Review (POCR) workflow for clients with final orders of removal who remain detained beyond the presumptively reasonable period. Tracks EOIR and ICE administrative record errors and generates correction request letters.
- POCR correction request letter generation with structured record error documentation
- Automated 90-day deadline tracking with alert notifications
- Integrated FOIA request generation to support record correction
DHS + DOJ Core Agencies
FOIA Requests
ICE · USCIS · CBP · EOIR · DHS
Matter-level FOIA tracking for DHS + component agencies (CBP, ICE, USCIS) + DOJ EOIR. Each request generates a properly addressed letter under the applicable CFR provision.
- Agency-specific request letter generation with correct regulatory citations
- Statutory response deadline tracking with alert triggers 3 days before expiration
- Appeal window tracking with 7-day advance alerts
Detention Intelligence
210+ facilities. Every federal circuit. Every ERO field office.
Selecting a detention facility at intake automatically populates circuit, field office, district court, and appropriate respondents.
ICE Detention Facilities
SPCs, CDFs, IGSAs, and DIGSAs — each facility mapped to their federal circuit, ERO field office, and district court. Facility type determines the custodian title used in generated documents.
ERO Field Offices
All Enforcement and Removal Operations field offices mapped to their responsible facilities and Field Office Directors — automatically applied as supplemental respondents where circuit rules permit.
District Courts
Federal district courts pre-mapped to their circuit and geographic jurisdiction. Petition headers and civil cover sheets populate the correct court information automatically.
Encoded Legal Logic
The rules are encoded. The math is exact.
Circuit-Specific Respondent Determination
Which respondents need to be named — and whether naming one is sufficient without the other — varies by circuit. Habeas Rabbit encodes each rule and enforces it at the respondent selection step:
9th Circuit — Armentero Rule
The Field Office Director may serve as the sole primary respondent. Naming only the immediate custodian warden is also permitted but not required.
6th Circuit — Roman Rule
Strict immediate custodian requirement. The facility warden must be named; the Field Office Director alone does not satisfy the custodian requirement.
Default Circuits — Padilla Standard
Flexible rule: the immediate custodian is required, with the Field Office Director as a supplemental respondent where appropriate.
National Respondents
The Secretary of DHS and Attorney General are listed as optional national respondents in all circuits.
Zadvydas Threshold Tracking
Per Zadvydas v. Davis, 533 U.S. 678 (2001), detention beyond 180 days absent significant likelihood of removal in the reasonably foreseeable future is presumptively unreasonable. Detention days aggregate across facility transfers — not just the current facility — tracked against both alert and threshold.
Detention Chronology Validation
Intake validates episode dates against one another, flagging chronological overlaps, impossible gaps, and inconsistencies before they propagate into filed documents.
Deadline Alert System
Critical threshold crossings — Zadvydas exceeded, overdue filing deadlines — deliver immediate email alerts. Non-critical matters (upcoming deadlines, FOIA windows) are consolidated into a daily digest to reduce practitioner notification fatigue.
Full Determination Logic
The complete decision path applied automatically when a detention facility is selected. National respondents are appended in every circuit.
Circuit, ERO field office, and district court auto-populated from facility
Circuit rule applied
9th Circuit
Armentero
FOD = primary
Warden = optional
6th Circuit
Roman
Warden = required
FOD = excluded
Default
Padilla
Warden = required
FOD = optional
National respondents appended (all circuits)
DHS Secretary · Attorney General · ICE Director
Document Generation
12+ templates. Generated client-side as DOCX.
All documents are generated in the browser using a centralized registry pattern. No data leaves your computer for document assembly. Generated files are standard DOCX format ready for editing and CM/ECF upload or printing.
Habeas Corpus Petition
28 U.S.C. § 2241
Order to Show Cause
District Court
Temporary Restraining Order
District Court
Civil Cover Sheet
JS-44
Summons
AO-440
Certificate of Service
District Court
Bond Motion
EOIR
Bond Motion Brief
EOIR
BIA Bond Appeal
Board of Immigration Appeals
POCR Correction Request
ICE
POCR FOIA Request
DHS
FOIA Requests (5 agencies)
ICE · USCIS · CBP · EOIR · DHS
Legal Data Standards
Structured data, not records in a proprietary system.
Every case created in Habeas Rabbit is automatically tagged against the noslegal v3.0 taxonomy — an open legal data standard — across eight facets. Labels applied at case creation. No extra input required.
noslegal v3.0 — Open Legal Taxonomy
noslegal is an open legal data standard providing a controlled vocabulary for classifying legal work. Version 3.0 of the taxonomy defines 192 official tags across eight facets, from applicable statutes and court types to participant roles and work product types.
Habeas Rabbit implements a focused subset of noslegal’s official vocabulary and extends the taxonomy with 107 custom U.S. immigration law IDs covering concepts specific to immigration detention practice — statutes, case law, facility types, POCR proceedings, and circuit-specific respondent roles — bringing the total vocabulary implemented in this system to 236 distinct identifiers.
FOLIO Semantic Layer — Planned
JSON-LD export against the Federated Open Legal Information Ontology (FOLIO) is on the roadmap. The case data model is structured with FOLIO in mind — matters, parties, documents, and relationships are designed to support JSON-LD expression, enabling future interoperability with FOLIO-aware legal information systems.
Case Created
Habeas Corpus — 28 U.S.C. § 2241
noslegal v3.0 applied automatically at creation — no additional input required from the practitioner.
Laws
Work Types
Participants
Places
resolved from facility
Info Assets
Sectors
Connectors
Work Elements
236 IDs across 8 facets — 192 official noslegal v3.0 + 44 custom immigration law extensions
Security and Compliance
Four layers of PII protection. Applied at every stage.
A-Number Protection
Alien Registration Numbers are masked in all API responses — returning only the last three digits in the format A-***-***-XXX. Full A-Numbers are never written to localStorage; users re-enter mid-intake if they refresh. Attorneys and admins may retrieve a full A-Number on demand via a gated, rate-limited, and audited action — the result is held in component state only, never persisted.
Immutable Audit Trail
Every sensitive action — case creation, document generation, status changes — is recorded in an append-only audit log. Entries are sanitized through an allowlist before write, ensuring A-Numbers, names, and case details never appear in the audit trail.
Encryption at Rest and in Transit
All traffic is encrypted in transit over TLS. Database storage uses AES-256 encryption at rest. Authentication is managed through Clerk with organization scoping — each organization's data is isolated at the query layer.
Implementation Detail
Where each layer applies
Browser storage isolation
partialize() zeroes A-Number before writing to localStorage — full value lives in memory only; cleared on page refresh
Encryption in transit
HTTPS · TLS 1.3 — all data encrypted between browser and server
API response masking
maskANumber() applied on every GET endpoint — A-***-***-789 returned; full A-Number never reaches client
Storage and log sanitization
PostgreSQL AES-256 at rest · sanitizeError() strips PII from error logs · audit trail records IDs only — zero sensitive fields written
The Name
Why Habeas Rabbit.
On February 1st, 2025, a federal judge ordered 5-year old Liam C.R. and his father released from the Dilley family detention center in Texas — the successful outcome of a habeas corpus petition filed by their attorney. Liam had been detained with his father after being ripped from their home in Minnesota.
The photos that circulated in the days that followed showed Liam in his blue bunny hat — a small detail that became one of the most widely recognized symbols of public solidarity during the federal government’s enforcement campaign in Minnesota.
Liam’s family name — his apellido paterno, is Conejo, which means 'Rabbit' in Spanish.
As of early 2026, roughly 70,000 people remain in ICE detention. Habeas Rabbit is built as the infrastructure for legal teams to move – or 'hop' – effectively across jurisdictional, operational, and procedural barriers — to scale access to justice for those still waiting.
Built By
Titus Consulting
Habeas Rabbit is a project of Titus Consulting, a legal design and technology studio based in Chicago. Titus helps attorneys and legal organizations build tools that bring structure and precision to complex legal services.