Francisco Coronel Mejia v. Brian D. Gardner, et al.

Summary

The United States District Court for the Northern District of Iowa denied Francisco Coronel Mejia’s petition for a writ of habeas corpus under 28 U.S.C. § 2241 and his motion for interim relief. The court held that an alien detained under 8 U.S.C. § 1225(b)(2) has no constitutional right to an individualized bond hearing under the circumstances presented. It also rejected his substantive due process challenge, while noting that prolonged or indefinite detention could raise different constitutional concerns.

Holdings

1. An alien who unlawfully entered the United States, was never inspected or admitted, and is detained under § 1225(b)(2) does not have a constitutional right to an individualized bond hearing while removal proceedings remain pending.
2. The petitioner's detention did not presently violate substantive due process because he had no deeply rooted fundamental right to release into the United States while removal proceedings were pending without having been lawfully admitted.
3. The petitioner was not entitled to habeas corpus relief or interim relief because his detention was constitutionally permissible at that time.

Questions Presented

1. Whether an alien detained under the mandatory-detention scheme of 8 U.S.C. § 1225(b)(2) has a procedural due process right to an individualized bond hearing during removal proceedings.
2. Whether continued civil detention under § 1225(b)(2), without an individualized bond hearing, violates substantive due process.
3. Whether the petitioner's detention was unlawful under 28 U.S.C. § 2241.

Disposition

dismissed