Alonso Magdaleno Rojas et al. v. Robert Lynch et al.

Summary

The United States District Court for the Western District of Michigan conditionally granted the immigration detainees’ petitions for writs of habeas corpus under 28 U.S.C. § 2241. The court held that 8 U.S.C. § 1226(a), rather than mandatory detention under § 1225(b)(2)(A), governed their detention and ordered bond hearings within five business days or immediate release.

Holdings

1. Prudential exhaustion does not bar Petitioners' § 2241 petition; alternatively, waiver of exhaustion is appropriate.
2. Section 1226(a), not the mandatory-detention provision in § 1225(b)(2)(A), governs noncitizens who have resided in the United States and were already within the country when apprehended and arrested.
3. Petitioners' current detention under the mandatory-detention framework of § 1225(b)(2)(A) violates the Fifth Amendment Due Process Clause.
4. The Detroit ICE Field Office Director is not the only proper Respondent; the court may retain both the Field Office Director and the Secretary of Homeland Security.

Questions Presented

1. Whether prudential exhaustion of administrative remedies should bar Petitioners' § 2241 challenge to their immigration detention.
2. Whether 8 U.S.C. § 1225(b)(2)(A), rather than 8 U.S.C. § 1226(a), governs the detention of noncitizens who had resided in the United States and were apprehended within the country.
3. Whether Petitioners' detention under the mandatory-detention framework of § 1225(b)(2)(A) violates the Fifth Amendment Due Process Clause.
4. Whether the Detroit ICE Field Office Director is the only proper Respondent in a § 2241 action challenging immigration detention.

Disposition

writ_granted