Miranda-Olivares v. Clackamas County, ___ F. Supp. 2d ___ (D. Or. Apr. 11, 2014) (8 CFR 287.7 does not require law enforcement to detain suspected noncitiens upon receipt of a Form I"247; county officials violated fourth amendment rights to due process by holding noncitizen in custody of jail solely on the basis of an immigration detainer, which constituted a new seizure; ICE detainer is not sufficient basis for jail to reasonably conclude it had probable cause to detain past the release date; county may be held liable for any period of unlawful detention), citing Galarza v. Szalczyk, 745 F.3d 634 (3d Cir. Mar. 4, 2014) (finding immigration detainers are not mandatory).