On June 7, 2016, the Court of Justice of the European Union ruled in Affum v. Préfet du Pas de Calais that non-EU citizens cannot be imprisoned for illegally crossing an internal Schengen area border before the return procedure has been completed. According to the press release, French police officers intercepted Sélina Affum, a citizen of Ghana, at the entry to the Channel Tunnel when she was travelling on board a bus from Belgium to London. There, she was taken into custody on grounds of her illegal entry into France and French authorities requested that Belgium readmit Affum into its territory. The Court noted that the Return Directive applied to this situation and that it “establishes common standards and procedures applicable in Member States for removing illegally staying nationals of non-EU countries from their territory.” The Directive requires that a decision be made regarding the return of the non-EU national, which triggers a period for voluntary return and is followed by forced removal if necessary. It allows detention of persons for up to eighteen months only to address a “risk of the removal being compromised.” French laws allow a prison penalty of one year for non-EU citizens who have entered France illegally. The Court noted that “illegal entry is one of the factual circumstances that may result in an illegal stay within the meaning of the Return Directive,” which triggers the procedures set out in it. It further ruled that “the Return Directive precludes any legislation of a Member State which lays down a sentence of imprisonment for an illegal stay of a national of a non-EU country in respect of whom the return procedure established by that directive has not yet been completed.” The Court also stressed that “the fact that Ms Affum was the subject of a procedure for readmission into the Member State from which she came (Belgium) does not render the directive inapplicable to her case,” rather, it “has the effect of transferring the obligation to apply the return procedure to the Member State responsible for taking the national back (in this instance, Belgium).” Finally, the Court noted that the applicability of the directive to this case was not affected by the facts that Affum was merely transiting through France or that she was arrested when she tried to leave the Schengen area.