J.C.V-R. v. Warden, Stewart Detention Center

J.C.V-R. · United States District Court for the Middle District of Georgia, Columbus Division · January 27, 2026 · No. 4:26-cv-00092-CDL-CHW

Summary

The court granted habeas relief under 28 U.S.C. § 2241 to the extent that the respondents must provide the petitioner, a detainee awaiting removal proceedings, with a bond hearing. The court determined that the petitioner was detained under 8 U.S.C. § 1226(a), rather than subject to mandatory detention under 8 U.S.C. § 1225(b)(2).

Court
United States District Court for the Middle District of Georgia, Columbus Division
Writing for the Court
Clay D. Land
Jurisdiction
United States District Court for the Middle District of Georgia, Columbus Division
Decision date
January 27, 2026
Docket number
4:26-cv-00092-CDL-CHW
Procedural posture
Petitioner sought habeas corpus relief under 28 U.S.C. § 2241 from immigration detention without a bond hearing while removal proceedings were pending.
Precedential value
unpublished
Parties
J.C.V-R. v. Warden, Stewart Detention Center
Disposition
writ_granted

Topics

immigration detentionfederal habeas corpusremoval proceedingsimmigration

Practice areas

immigration detentionfederal habeas corpusremoval proceedings

Questions Presented

  1. Whether petitioner was subject to mandatory detention under 8 U.S.C. § 1225(b)(2) or was detained under 8 U.S.C. § 1226(a).
  2. Whether petitioner was entitled to a bond hearing to determine eligibility for release under 8 U.S.C. § 1226(a)(2) and applicable regulations.

Holdings

  1. Petitioner was detained under 8 U.S.C. § 1226(a) and therefore was not subject to mandatory detention under 8 U.S.C. § 1225(b)(2).
  2. Respondents must provide petitioner with a bond hearing to determine whether petitioner may be released on bond under 8 U.S.C. § 1226(a)(2) and applicable regulations.

Key quotations

Accordingly, Petitioner’s application for habeas corpus relief is granted to the extent that Respondents shall provide Petitioner with a bond hearing to determine if the Petitioner may be released on bond under § 1226(a)(2) and the applicable regulations.

Factual background

Petitioner was detained at the Stewart Detention Center while awaiting removal proceedings. Respondents had refused to provide a bond hearing or an opportunity for pre-removal release, asserting that petitioner was subject to mandatory detention under 8 U.S.C. § 1225(b)(1) and/or § 1225(b)(2). The court determined that petitioner was instead detained under 8 U.S.C. § 1226(a).

Procedural history

J.C.V-R., detained at the Stewart Detention Center and awaiting removal proceedings, filed an application for habeas relief challenging the refusal to provide a bond hearing and an opportunity for pre-removal release. Respondents argued that detention was mandatory under 8 U.S.C. § 1225(b)(1) and/or § 1225(b)(2). The court concluded that petitioner was detained under 8 U.S.C. § 1226(a) and granted relief to the extent of ordering a bond hearing.

Remand instructions

Respondents shall provide petitioner with a bond hearing to determine whether petitioner may be released on bond under 8 U.S.C. § 1226(a)(2) and applicable regulations.

Court Document

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