Edgar Agustin Moctezuma Macias v. Brian Henkey, Field Office Director of Enforcement and Removal Operations, Salt Lake City Field Office, Immigration and Customs Enforcement; Kenneth Porter, Acting Director of the Boise U.S. Immigration and Customs Enforcement Field Sub-Office; Kristi Noem, Secretary, U.S. Department of Homeland Security; Pamela Bondi, U.S. Attorney General; Michael Hollingshead, Sheriff of Elmore County

Summary

The United States District Court for the District of Idaho granted Edgar Agustin Moctezuma Macias’s motion for a temporary restraining order challenging his mandatory detention under 8 U.S.C. § 1225. The court concluded that § 1225 does not apply to a noncitizen who entered the United States years earlier and was apprehended while residing in the country, and ordered his immediate release. Respondents were ordered to respond to the habeas petition by January 12, 2026.

Holdings

1. The district court had jurisdiction to review Petitioner's challenge to detention without a bond hearing, although it lacked jurisdiction to review the underlying removal proceedings themselves.
2. Section 1225(b)(2)(A) does not authorize mandatory detention of a person who entered the United States years earlier, established residence in the country, and was apprehended while living in the interior rather than actively seeking admission.
3. Petitioner satisfied the requirements for a temporary restraining order because he was likely to succeed on his detention claim, continued detention would cause irreparable harm, the equities favored him, and relief served the public interest.
4. Immediate release, rather than merely a bond hearing, was an appropriate and narrowly tailored remedy because Petitioner had no criminal history, had strong family ties and nearly thirty years of residence, and was not shown to be a flight risk or danger to the community.

Questions Presented

1. Whether the district court had subject-matter jurisdiction over Petitioner's habeas challenge to detention without a bond hearing.
2. Whether 8 U.S.C. § 1225(b)(2)(A) authorizes mandatory detention of a noncitizen who entered without inspection decades earlier and was apprehended while residing in the interior of the United States.
3. Whether Petitioner satisfied the four-factor standard for a temporary restraining order.
4. Whether immediate release, rather than a bond hearing, was the narrowly tailored remedy for the alleged unlawful detention.

Disposition

other