Summary
The United States District Court for the Western District of Pennsylvania granted Darwin Diaz Turcios’s habeas petition under 28 U.S.C. § 2241 insofar as it sought a bond hearing. Applying the Third Circuit’s framework for prolonged immigration detention under German Santos v. Warden Pike County Correctional Facility, the Court held that Petitioner was entitled to a constitutionally adequate individualized bond hearing before an immigration judge. The Court denied the motion for preliminary injunction as moot, adopted the magistrate judge’s report and recommendation, and ordered the case closed.
Court
United States District Court for the Western District of Pennsylvania
Jurisdiction
United States District Court for the Western District of Pennsylvania
Decision date
June 2, 2026
Docket number
3:25-cv-083
Disposition
other
Questions Presented
- Whether petitioner's prolonged detention under 8 U.S.C. § 1226(c) entitled him to a constitutionally adequate bond hearing notwithstanding the statute's restrictions on release.
- Whether the petition should be granted to require an individualized bond hearing before an immigration judge.
- Whether petitioner's motion for a preliminary injunction should be denied as moot after habeas relief requiring a bond hearing was granted.
Holdings
- An alien detained under § 1226(c) is not categorically ineligible for an as-applied due process review of prolonged detention. Substantive and procedural due process considerations are intertwined, and the statute does not preclude a bond hearing when the Constitution requires one.
- Petitioner was entitled to a constitutionally adequate, individualized bond hearing before an immigration judge to determine whether he posed a flight risk or danger to the community.
- The motion for a preliminary injunction was denied as moot.
Court Document
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