Miguel Eduardo Ylarraza-Trejo v. Warden, Boone County Jail, et al.

Summary

The United States District Court for the Eastern District of Kentucky granted Miguel Eduardo Ylarraza-Trejo’s habeas petition, concluding that 8 U.S.C. § 1226(a), rather than § 1225, governed his immigration detention. The court held that detention without an individualized custody hearing violated due process and ordered Respondents to release him or provide a constitutionally adequate bond hearing within seven days, with the government bearing the burden of proof by clear and convincing evidence. Respondents were also ordered to file a status report by June 15, 2026.

Holdings

1. Section 1226(a) governs the detention of a noncitizen like petitioner who is not seeking admission because he entered the United States years earlier, was released into the country, and was later detained within the country.
2. Petitioner's detention without access to an individualized hearing violated the Fifth Amendment's Due Process Clause.
3. The proper remedy was immediate release or, alternatively, a constitutionally adequate bond hearing under § 1226(a) at which the government bears the burden of proving dangerousness or flight risk by clear and convincing evidence.

Questions Presented

1. Whether 8 U.S.C. § 1226(a), rather than the mandatory-detention provisions of 8 U.S.C. § 1225, governed petitioner's immigration detention.
2. Whether detaining petitioner without access to an individualized bond hearing violated the Fifth Amendment's Due Process Clause.
3. Whether the proper remedy was immediate release or a constitutionally adequate bond hearing at which the government bears the burden of proof by clear and convincing evidence.

Disposition

writ_granted