Rodrigo M. v. Pamela Bondi, et al.

Rodrigo M. · United States District Court for the District of Minnesota · February 8, 2026 · No. No. 26-cv-1069 (KMM/LIB)

Summary

The United States District Court for the District of Minnesota granted in part and denied in part a habeas petition challenging the detention of an individual arrested by federal immigration authorities. The court held that mandatory detention under 8 U.S.C. § 1225(b)(2) did not apply, but that detention under 8 U.S.C. § 1226(a) was authorized because the petitioner was arrested pursuant to a warrant. The court ordered respondents to provide a bond hearing by February 13, 2026.

Holdings

  1. Section 1225(b)(2) does not apply to aliens already in the United States who are not seeking admission; therefore, Rodrigo M. was not subject to mandatory detention under that provision.
  2. An arrest pursuant to an Attorney General's warrant gives the government authority to detain Rodrigo M. under § 1226(a), but a person detained under that provision is entitled to a bond hearing at the outset of detention.

Questions Presented

  1. Whether 8 U.S.C. § 1225(b)(2)'s mandatory-detention provision applies to an alien already present in the United States who is not seeking admission.
  2. Whether an arrest pursuant to a warrant under 8 U.S.C. § 1226(a) authorizes detention without immediate release.
  3. Whether an alien detained under § 1226(a) is entitled to a bond hearing at the outset of detention.

Disposition

other

Cases Cited (3)

  • Belsai D.S. v. Bondi, No. 25-cv-03682 (KMM/EMB), 2025 WL 2802947 (D. Minn. Oct. 1, 2025)(followed)
  • Jose J.O.E. v. Bondi, 797 F. Supp. 3d 957, 961 (D. Minn. 2025)(followed)
  • Jennings v. Rodriguez, 583 U.S. 281, 306 (2018)(followed)

Cited In (0)

No citing cases on record yet.

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