Question juridique clé
Whether the prior administrative detention was still in force when the new detention order was issued, making the new detention null or unlawful.
Solution extraite
The prior administrative detention had been lifted when the applicant was transferred to penal custody; there was no overlap, so the new detention was based on a valid title.
Motifs extraits
The cantonal finding that detention was lifted on 2012-02-16 was not arbitrary. The transfer from administrative detention to prison necessarily implied a different custody title and the end of administrative detention under Art. 80(6)(c) LEtr.