Oscar Eligio Amaya v. Kevin Raycraft, Immigration and Customs Enforcement, Detroit Field Office, Field Office Director of Enforcement and Removal Operations, et al.

Summary

The United States District Court for the Eastern District of Michigan granted Oscar Eligio Amaya’s petition for a writ of habeas corpus and dismissed all respondents except ICE Field Office Director Kevin Raycraft. The court held that 8 U.S.C. § 1226(a), rather than § 1225(b)(2), governs Amaya’s detention and ordered Raycraft to provide a bond hearing or release Amaya by December 17, 2025. The court also granted the ACLU of Michigan leave to file an amicus curiae brief and ordered a status report.

Holdings

1. The Eastern District of Michigan had jurisdiction over the petition, and the ICE Detroit Field Office Director, Kevin Raycraft, was a proper respondent because he exercised operational control over Amaya's immigration detention within the district.
2. The court would not require Amaya to exhaust administrative remedies before seeking habeas relief.
3. 8 U.S.C. § 1226(a), rather than 8 U.S.C. § 1225(b)(2), governed Amaya's detention because he had long been present in the United States and was not seeking admission.
4. Because Amaya was detained under § 1226(a) and had not received a bond hearing, his custody violated federal law, entitling him to habeas relief.

Questions Presented

1. Whether the federal district court had jurisdiction over Amaya's immigration habeas petition in the Eastern District of Michigan when the warden of the county jail where he was detained was not named as a respondent.
2. Whether respondents other than the ICE Detroit Field Office Director were proper respondents to the immigration habeas petition.
3. Whether the court should require Amaya to exhaust administrative remedies by appealing the immigration judge's denial of bond before seeking habeas relief.
4. Whether 8 U.S.C. § 1225(b)(2), which provides for mandatory detention of certain aliens seeking admission, governed Amaya's detention, or whether 8 U.S.C. § 1226(a) governed because he had long been present in the United States and was facing removal.
5. Whether Amaya's detention without a bond hearing violated federal law.

Disposition

writ_granted