Courts agree that the federal government may not seize a person in the United States and immediately ship them off to a prison in another country without providing any opportunity for judicial review. But this basic constitutional rule has proven difficult to enforce in court. The challenge comes not only from a defiant Executive Branch, secret orders, and midnight transfers, but also defense-side agency forum shopping. As soon as the Supreme Court held that challenges to designation and removal under the Alien Enemies Act must be brought in the district of confinement, the federal government moved detainees away from districts issuing protective orders to districts that have declined to act, necessitating a dramatic late-night intervention from the Supreme Court. This story is an especially vivid example of defense-side Executive Branch forum shopping, a phenomenon that has gone largely unnoticed and unstudied.