Elsa Maria Zuna Bravo v. Superintendent, Strafford County Dept. of Corrections, et al.

2026 DNH 065 (D. N.H. 2026) · United States District Court for the District of New Hampshire · June 1, 2026 · No. 26-cv-386-SM-TSM

Summary

The United States District Court for the District of New Hampshire partially granted Elsa Maria Zuna Bravo’s habeas petition under 28 U.S.C. § 2241. The court ordered respondents to provide her with a constitutionally adequate bond hearing before an immigration judge, with specified burdens of proof, but denied without prejudice her request for immediate release.

Holdings

  1. Bravo was entitled to a constitutionally adequate bond hearing before an immigration judge as soon as practicable.
  2. Bravo was not entitled at this stage to an order directing her immediate release; that request was denied without prejudice.

Questions Presented

  1. Whether Bravo was entitled under 28 U.S.C. § 2241 to a constitutionally adequate bond hearing before an immigration judge.
  2. Whether Bravo was entitled to immediate release from immigration custody.

Disposition

other

Cases Cited (3)

  • Guerrero Orellana v. Moniz, No. 25-cv-12664-PBS, 2025 WL 3687757, at *10-11 (D. Mass. Dec. 19, 2025)(not_followed_or_not_resolved)
  • Destino v. FCI Berlin, Warden, No. 25-cv-374-SE-AJ, 2025 WL 4010424 (D.N.H. Dec. 24, 2025)(followed)
  • Hernandez-Lara v. Lyons, 10 F.4th 19, 41 (1st Cir. 2021)(followed)

Cited In (0)

No citing cases on record yet.

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