Marlon Josue Ramos-Medina a/k/a Darwin Javier Diaz Medina v. Brian English, et al.

Summary

The United States District Court for the Northern District of Indiana conditionally granted an immigration detainee’s 28 U.S.C. § 2241 petition. The court held that 8 U.S.C. § 1225(b)(2) did not mandate detention for a noncitizen arrested within the United States years after entry and that detention was instead governed by 8 U.S.C. § 1226(a). It ordered the respondents to provide an individualized bond hearing or release the petitioner by May 1, 2026, and declined to reach his constitutional claims.

Holdings

1. The mandatory-detention provision in 8 U.S.C. § 1225(b)(2) does not apply to a noncitizen who is arrested within the interior of the United States years after arriving there rather than while seeking admission at a port of entry.
2. Because petitioner was arrested pursuant to a warrant and could not be detained under § 1225(b)(2), he was entitled to a prompt individualized bond hearing under 8 U.S.C. § 1226(a) and its implementing regulations.
3. Exhaustion did not bar petitioner from obtaining § 2241 relief because exhaustion is not statutorily mandated and pursuing an administrative bond request would have been futile under the government's categorical position that individuals like petitioner were ineligible for bond.

Questions Presented

1. Whether 8 U.S.C. § 1225(b)(2)'s mandatory-detention provision applies to a noncitizen who entered without inspection but was arrested by ICE in the interior of the United States years after arrival.
2. Whether petitioner was entitled to an individualized bond hearing under 8 U.S.C. § 1226(a).
3. Whether exhaustion of administrative remedies barred § 2241 relief.
4. Whether the court needed to decide petitioner's alternative Due Process Clause challenge or his argument concerning the allocation of the burden at a bond hearing.

Disposition

writ_granted