Saray Ruiz Linares v. Christopher Bullock

Summary

The United States District Court for the Western District of Tennessee granted Saray Ruiz Linares’s 28 U.S.C. § 2241 habeas petition challenging her detention without a bond hearing. The court held that 8 U.S.C. § 1226(a), rather than the mandatory-detention provision in § 1225(b)(2)(A), governed her detention because she had been continuously present in the United States for more than three years. The court ordered her immediate release and enjoined the respondent from detaining her under § 1225(b)(2)(A).

Holdings

1. Exhaustion was excused because the petition presented a purely legal question, delay threatened prolonged potentially unlawful detention and hardship, and resort to the administrative process would be futile in light of the BIA's stated position.
2. The detention of an undocumented immigrant who had been continuously present in the United States for more than two years and was arrested away from the border was governed by § 1226(a), not § 1225(b)(2)(A).
3. Ruiz Linares's detention without a bond hearing violated the Fifth Amendment Due Process Clause.
4. The petition was granted; Ruiz Linares was entitled to immediate release, and the respondent was enjoined from detaining her under § 1225(b)(2)(A).

Questions Presented

1. Whether prudential exhaustion of administrative remedies should be required or excused for the § 2241 challenge to detention without a bond hearing.
2. Whether 8 U.S.C. § 1225(b)(2)(A) or § 1226(a) governs the detention of a noncitizen who has been continuously present in the United States for more than two years and was arrested away from the border.
3. Whether detention without a bond hearing violated Ruiz Linares's Fifth Amendment due process rights.
4. Whether the detention violated the Fourth or Eighth Amendments.

Disposition

writ_granted