# Yirenkyi

> District Court, M.D. Pennsylvania · February 2, 2026

URL: https://www.frixlaw.com/law-library/cases/11251155

## Case

- **Full name:** Emmanuel S. Yirenkyi v. Angela Hoover, Warden of the Clinton County Correctional Facility, et al.
- **Court:** District Court, M.D. Pennsylvania
- **Decided:** February 2, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
EMMANUEL S. YIRENKYI, : No. 3:25cv2414
Petitioner :
: (Judge Munley)
V. :
ANGELA HOOVER, Warden of the :
Clinton County Correctional Facility, :
et al., :
Respondents :

MEMORANDUM
Emmanuel S. Yirenkyi is an immigration detainee in the custody of the
United States Department of Homeland Security (“DHS”), Immigration and
Customs Enforcement (“ICE”). He is currently detained at the Clinton County
Correctional Facility in McElhattan, Pennsylvania pursuant to an
intergovernmental service agreement.
Yirenkyi commenced this action by filing a petition for a writ of habeas

corpus under 28 U.S.C. § 2241.' (Doc. 1). Yirenkyi seeks immediate release

1 Like many recent filings by pro se litigants, Yirenkyi’s petition and traverse were drafted with
the aid of generative artificial intelligence. The court sees two issues with petitioner's reliance
Al. First, his petition analyzes several seminal cases but omits controlling Third Circuit
case law, German Santos v. Warden Pike Cnty. Corr. Facility, 965 F.3d 203 (3d Cir. 2020).
Second, and more troublesome, Yirenkyi’s traverse cites cases from the Middle District of
Pennsylvania which do not exist—further examples of legal hallucinations created by large
language models. (See Doc. 11 at 7 (citing “Frederick v. Warden, 2019 WL 1318445 (M.D. Pa
Mar. 22, 2019)” and “Rodriguez v. Lowe, 2018 ‘WL 683974 (M.D.Pa. Feb. 2, 2018)”). Yirenkyi
cites these two cases to argue that “[c]ourts have found detention in the 8-10 month range
constitutionally significant and requiring a release or a bond hearing[.]” Id. Although
“Rodriguez” would appear to involve a detainee held at the Pike County Correctional Facility

from detention under conditions of supervision. In the alternative, he seeks a

“constitutionally compliant” bond hearing with an immigration judge (“lJ”).
“(T]he Fifth Amendment entitles aliens to due process of law in deportation
proceedings.” Reno v. Flores, 507 U.S. 292, 306 (1993). Based on the record

and for the reasons discussed below, due process compels a bond hearing with

an IJ conducted in accordance with German Santos v. Warden Pike Cnty. Corr.

Facility, 965 F.3d 203 (3d Cir. 2020).
Background
Yirenkyi was born in Ghana in 1994. (Doc. 1-5). He has lived in the
United States since December 31, 2012. Id. He was issued a permanent
resident card by United States Customs and Immigration Services. Id. Yirenkyi
has a four-year-old child, a United States citizen. (Doc. 1-6). He asserts that he
is the only caregiver for his mother. (Doc. 1 at ECF p. 14).
On September 13, 2023, Yirenkyi pled guilty to conspiracy to commit bank
fraud and conspiracy to commit access device fraud in the United States District
Court for the District of New Jersey, United States v. Yirenkyi, No. 1:23-CR-723-

where Craig Lowe is the warden, the Westlaw citation provided for that “case” directs to a
family court decision from Québec (in French). No case in this district stands for the
proposition that detention in the 8-10 month range requires release or a bond hearing, at least
since German Santos was decided in July 2020. To be sure, the court has researched
decisions from the Middle District of Pennsylvania since that time and supplied its findings in
an appendix to this memorandum. In this instance, no show cause order will be issued
regarding any possible sanctionable conduct. The petitioner is pro se, in ICE custody at a
county jail, and appears to be relying on outside sources to supply him with legal materials.

CPO-1 (D.N.J.), (Doc. 8-3 at 13). The Honorable Christine P. O’Hearn
sentenced the petitioner to six (6) months imprisonment in August 2024.? Id. at
14. Judge O’Hearn further sentenced petitioner to a five (5) year term of
supervised release. Id. at 15. Yirenkyi is thus a convicted felon.
The judgment in his criminal case indicates that Yirenkyi is subject to
special conditions of supervised release, including the Location Monitoring
Program administered by U.S. Probation. Id. at 15. Specifically, he must submit
to home detention for a period of six (6) months, but is able to leave his
residence for employment, education, and religious services. Id. He is required
to undergo mental health treatment in a program approved by the U.S. Probation
Office. Id. A condition of supervised release also includes cooperation with ICE.
Id.
Following his conviction and sentence, Yirenkyi was charged with being a
removable alien pursuant to 8 U.S.C. § 1227(a)(2)(A)(iii). (Doc. 8-1). In the
removal proceedings, the government alleges that petitioner's conviction was an
aggravated felony, i.e., that the loss in his case exceeded $10,000. Id.
On April 7, 2025, an IJ ordered the petitioner removed to Ghana. (Doc. 8-
4). Yirenkyi then appealed to the Bureau of Immigration Appeals (“BIA”). On

2 Defendant filed a pro se appeal of his conviction and sentence in February 2025. That
appeal remains pending. See United States v. Yirenkyi, No. 25-1294 (3d Cir.).

September 30, 2025, the BIA denied his appeal. (Doc. 8-6). Yirenkyi
subsequently filed a Petition for Review with the United States Third Circuit Cour
of Appeals. ° A temporary stay of removal has been entered by the appellate
court pending full consideration of Yirenkyi’s motion to stay. See United States v.
Yirenkyi, No. 25-3113 (3d Cir.), (Doc. 3).
On December 15, 2025, Yirenkyi filed a petition for a writ of habeas corpus
pursuant to 28 U.S.C. § 2241 challenging his continued immigration detention.
(Doc. 1). In that petition, Yirenkyi seeks immediate release or an individualized
bond hearing before an IJ. Id. The government filed a response to the petition or
January 6, 2026, (Doc. 8), and the Clerk of Court docketed Yirenkyi’s traverse on
January 27, 2026, (Doc. 11).
From the record provided by respondents, Yirenkyi has been in ICE
custody since April 15, 2025, or presently for 9.5 months. (Doc. 8-1 at 1; Doc. 8
at 8, Doc. 8-7, BOP Inmate Locator Result). This is generally not considered an
unreasonable amount of time in immigration detention. However, due primarily
to the conditions of confinement and the supervised release provisions in
Yirenkyi’s criminal sentence, the petition for writ of habeas corpus will be

3 Claims regarding the length of immigration detention without a bond hearing do not get
funneled into the Petition for Review process. Khalil v. President, United States, No. 25-2162, -
-- F.4th ----, 2026 WL 111933, at *12 (3d Cir. Jan. 15, 2026)

granted. In this petitioner’s specific circumstances, his detention has become
unreasonable, and he has a due process right to a bond hearing.
Jurisdiction
Under 28 U.S.C. § 2241(c), a prisoner or detainee may receive habeas
relief when he “is in custody in violation of the Constitution or laws or treaties of
the United States.” See 28 U.S.C. § 2241(c)(3); Maleng v. Cook, 490 U.S. 488,
490 (1989). Yirenkyi filed the instant petition while he was detained within the
jurisdiction of this court. He remains in ICE custody at the Clinton County
Correctional Facility. Clinton County is located within the boundaries of the
United States District Court for the Middle District of Pennsylvania. 28 U.S.C. §
118(b). Consequently, the court has jurisdiction over his Section 2241 petition.
See 28 U.S.C. § 2241(a) (“Writs of habeas corpus may be granted by...the
district courts...within their respective jurisdictions.”).
Analysis
Yirenkyi contends that his immigration detention has become prolonged
and unconstitutional. Based on the government’s response to the petition and
the case law cited by Yirenkyi, the parties agree that he is currently detained
pursuant to 8 U.S.C. § 1226(c). Section 1226(c) applies to the detention of a
“criminal alien,” including those who are “deportable by reason of having

committed any offense covered” in 8 U.S.C. § 1227(a)(2)(A)(iii), the provision the

government argues is applicable to Yirenkyi.*
Section 1226(c) does not limit the length of the detention it authorizes,
Jennings v. Rodriguez, 583 U.S. 281, 303 (2018), but “a petitioner may still bring

an as-applied constitutional challenge alleging that his continued detention has
become unconstitutional under the Due Process Clause of the Fifth Amendment.
Ibrahim v. Superintendent of Miami Corr. Facility, No. 1:25-CV-00727, 2026 WL
116489, at *4 (M.D. Pa. Jan. 15, 2026) (Wilson, J) (citing German Santos, 965
F.3d at 208-09); see also Zadvydas v. Davis, 533 U.S. 678, 690 (2001)
(“statute[s] permitting indefinite detention of an alien would raise a serious
constitutional problem’). In such as-applied challenges, “when detention
becomes unreasonable, the Due Process Clause demands a hearing.” German
Santos, 965 F.3d at 210 (quoting Diop v. ICE/Homeland Sec., 656 F.3d 221, 233
(3d Cir. 2011), abrogated in part on other grounds by Jennings, 583 U.S. at 304-
05.°

4 An “alien” means any person not a citizen or national of the United States. 8 U.S.C. §
1101(a)(3). “Any alien who is convicted of an aggravated felony at any time after admission is
deportable.” 8 U.S.C. § 1227 (a)(2)(A)(iii). An “aggravated felony” includes “an offense
that...involves fraud or deceit in which the loss to the victim or victims exceeds $10,000.” 8
U.S.C. § 1101(a)(43)(M).
5 Jennings did not call into question the holding in Digan that detention under Section 1226 may
violate due process if unreasonably long. Borbot v. vivarden Hudsor Cinty. Carr Facility, 906
F.3d 274, 278 (3d Cir. 2018).

The question to be answered is whether the petitioner’s detention is
reasonable—‘“a ‘highly fact-specific’ inquiry.” Id. (quoting Chavez-Alvarez v.
Warden York Cty. Prison, 783 F.3d 469, 474 (3d Cir. 2015), abrogated in part on
other grounds by Jennings, 583 U.S. at 304—05).® In this circuit, there is a non-
exhaustive list of four factors to consider in assessing whether an alien’s
detention has grown unreasonable: 1) duration of detention; 2) whether the
detention is likely to continue; 3) the reasons for the delay; and 4) whether the
conditions of confinement are meaningfully different from criminal confinement.
Id. at 211 (citations omitted). By its very nature, the use of a balancing
framework makes any determination of reasonableness a fact-intensive
proposition. See Chavez-Alvarez, 783 F.3d at 474.
Duration of Detention — Duration of detention is the most important factor.
German Santos, 965 F.3d at 211. Under the case law, “[t]here is no presumptior
of reasonableness or unreasonableness of any duration.” German Santos, 965
F.3d at 211 (citing Chavez-Alvarez, 783 F.3d at 474 n.7; Diop, 656 F.3d at 234).
After five (5) months, however, “the constitutional case for continued detention
without inquiry into its necessity becomes more and more suspect as detention

6 Jennings did not abrogate the holdings in Diop and Chavez-Alvarez that Section 1226(c) is
unconstitutional “when applied to detain an alien an unreasonably long [time] without a bond
hearing.” German Santos, 965 F.3d at 210.

continues[.]” Diop, 656 F.3d at 234 (discussing Demore v. Kim, 538 U.S. 510,
530 (2003)).
With respect to the first and most important consideration, Yirenkyi has
been detained by DHS since at least April 15, 2025, or 9.5 months. At least one
court within the appellate jurisdiction of the Third Circuit has determined that a
nine-month period was an unreasonably long time where DHS appealed an lJ
decision granting asylum and there was “no end in sight” to the detention.
Mashchenko v. Rokosky, No. CV 25-12387 (RK), 2026 WL 185204, at *3 (D.N.J.
Jan. 25, 2026) (Kirsch, J.) (quoting German Santos, 965 F.3d at 213) (applying
factors to Section 1225(b) family-separation detention); see also A.L. v. Oddo,
761 F. Supp. 3d 822, 826 (W.D. Pa. 2025) (holding that detention of ten months
weighed in favor of a bond hearing for a 1225(b) detainee under the German
santos factors).
Such cases appear to be outliers when compared to decisions within the
Middle District of Pennsylvania. See Appx. Because 9.5 months is less than the
periods typically found unreasonable in this district, the undersigned finds that
the duration factor weighs against relief at this time.
With that said, there are no bright lines in the reasonableness analysis. See
Chavez-Alvarez, 783 F.3d at 474, n.7. The Fifth Amendment requires a more
granular look at the other facts of this case.

Likelihood of Continued Detention — As to whether detention will
continue, the court finds that Yirenkyi’s detention will continue into the
foreseeable future. Yirenkyi is detained on a pre-final order of removal. His
appeal to the BIA was summarily dismissed for “not contain[ing] statements that
meaningfully apprise the Board of specific reasons underlying the challenge to
the [IJ’s] decision.” (Doc. 8-6 at ECF p. 4). His appeal of the BIA decision has
been pending with the Third Circuit since October 2025. A motion to stay
removal has also been pending since that time. The court cannot reasonably
determine how long Yirenkyi’s appeal will be pending before the Third Circuit or
forecast whether it will be remanded. There will be a delay of undefined
duration. See Davydov v. Doll, No. 1:19-CV-2110, 2020 WL 969618, at *5 (M.D.
Pa. Feb. 28, 2020) (Kane, J). “When the alien's removal proceedings are
unlikely to end soon, this suggests that continued detention without a bond
hearing is unreasonable.” German Santos, 965 F.3d at 211 (3d Cir. 2020).
Consequently, this factor weighs in favor of relief.
Reasons for the Delay - The third factor considers the reasons for the
delay, “such as a detainee's request for continuances.” Id. (citing Diop, 656 F.3d
at 234; Demore, 538 U.S. at 531). The court also asks, “whether either party
made careless or bad-faith ‘errors in the proceedings that cause[d] unnecessary
delay.’ ” Id. (quoting Diop, 656 F.3d at 234).

In this case, the government has indicated that Yirenkyi’s conduct
prevented meaningful review by the BIA because he did not file the proper
supporting documents. (Doc. 8 at 3). However, from the BIA decision, it appears
that Yirenkyi’s such conduct may have been attributable to lapses with the
attorneys the petitioner hired to represent him. (Doc. 6). Consequently, the court
cannot call such conduct “bad faith.” Therefore, because the petitioner has also
not demonstrated that the government has acted in bad faith, this factor is
neutral. See German Santos, 965 F.3d at 212.
Conditions of Confinement — This factor requires a determination of
whether “the alien's conditions of confinement are meaningfully different from
criminal punishment.” Id. at 211 (cleaned up). Under the law, “if an alien's civil
detention under § 1226(c) looks penal, that tilts the scales toward finding the
detention unreasonable.” Id. (citing Chavez-Alvarez, 783 F.3d at 478) (emphasis
added).
The Clinton County Correctional Facility is a county jail. A jail is a jail and
there is no evidence that Yirenkyi is treated any different than the criminal pretria
detainees in county lockup or those inmates serving state criminal sentences of
shorter durations. Therefore, Yirenkyi’s detention is indistinguishable from
criminal punishment. See id. at 213 (regarding the conditions at Pike County

40

Correctional Facility); see also Chavez-Alvarez, 783 F.3d at 478 (regarding the

conditions at York County Prison).
Additionally, the “conditions of confinement” factor and “length of detention
factors are interdependent parts of the German Santos reasonableness test.
See 965 F.3d at 211 (citing Chavez-Alvarez, 783 F.3d at 478) (“And as the lengftl
of detention grows, so does the weight that” courts must give to the conditions of
confinement factor). Put another way, with the interdependence of factors, the

more conditions look like a jail sentence as confinement continues, the more the
court must worry about due process. Id. at 212-13. Here, Yirenkyi has been hel
at a county jail for over nine (9) months without bail for an alleged violation of civ!
law. In Yirenkyi’s case, this factor weighs in favor of granting relief.
Other Considerations — German Santos further sets forth that its four
factors are a non-exhaustive list of considerations. Id. at 210. Given the

purposes of Section 1226(c), the statute that Yirenkyi is being detained under,
the court considers whether detention without bond in Yirenkyi’s specific case
“necessarily serves the purpose of preventing deportable criminal aliens from
fleeing prior to or during their removal proceedings, thus increasing the chance
that, if ordered removed, [petitioner] will be successfully removed.” Demore, 538
U.S. at 528. Therefore, the court takes a step back and looks at the whole

44

picture. This birds-eye view reveals some inconsistencies within the federal
system with respect to the petitioner.
First, a federal judge in Yirenkyi’s criminal case granted him bond and
allowed him to report to prison voluntarily. The government trusted Yirenkyi to
get himself from New Jersey to a federal prison in the center of Pennsylvania.
Second, the Federal Bureau of Prisons (a federal law enforcement agency
under the United States Department of Justice) evaluated Yirenkyi and assigned
him to a low-security prison. In the criminal world, the BOP decided that he was

a low risk. From the record provided by respondents, Yirenkyi fully served his
federal prison sentence without incident in a prison environment with lower
security measures. Yet, in the civil immigration world, ICE (a federal law
enforcement agency under DHS) keeps Yirenkyi in a county Jail.
Third, in the absence of an ICE detainer, Yirenkyi would be subject to five

years of supervised release by the U.S. Probation Office with at least the first six
(6) months spent on a strict location monitoring program. (Doc. 8-3, ECF p. 16).
Upon leaving prison, Yirenkyi would have to report to U.S. Probation to be fitted
for an ankle monitor and to meet with his probation officer. Instead, the petitione
is awaiting removal proceedings behind bars under the watch of a local
government’s prison guards. This is an irrational outcome. In a balancing test,
such irrationality weighs against continued detention without a bond hearing.

49

Weighing the Factors — While Yirenkyi has been held in detention for 9.5
months—a fact that weighs against him—the remaining circumstances reveal
that his detention has become unreasonable. Yirenkyi’s petition for a writ of
habeas corpus will be granted.
Although Yirenkyi has requested his release, the order issued in this case
will not grant that request. Rather, the petitioner is entitled to a timely bond
hearing with an IJ where the government will bear the burden to justify his
continued detention by clear and convincing evidence. German Santos, 965
F.3d at 214. The court will add one caveat. If the government does not provide
Yirenkyi with a bond hearing within thirty (30) days, the petitioner will be ordered
released and directed to comply with the supervised release provisions of the
criminal sentence imposed on him by the United States District Court for the
District of New Jersey.
Conclusion
Based on the foregoing, the court will grant Yirenkyi’s petition for a writ of
habeas corpus pursuant to 28 U.S.C. § 2241 and enter an appropriate order
the terms discussed in this memorandum.

aff
Date: Pecan Ne
ted Staten K. MUNLEY
d States District Court

42

| APPENDIX
| Case Approximate Factor —_| Disposition

Shonhai v. Lowe, No. CV 3:24-229, | 24 months Weighs in Bond
|} 2025 WL 510975, at *5 (M.D. Pa. favor of relief | hearing
Feb. 14, 2025) (Mannion, J.). granted
| Ologbenla v. Lowe, No. 3:25-CV- 24 months Weighs in Bond
|| 1351, 2025 WL 2375272, at *3 favor of relief | hearing
|| (M.D. Pa. Aug. 14, 2025) (Munley, granted
J,).
|| Barradas-Jacome v. Lowe, No. 22 months Weighs in Bond
|| 1:22-CV-1412, 2023 WL 2742741, favor of relief | hearing
at *3 (M.D. Pa. Mar. 31, 2023) denied
(Conner, J.).
Diahn v. Lowe, No. 1:24-cv-1936, 19 months Weighs in Bond
|| 2025 WL 2115442, at *4 (M.D. Pa. favor of relief | hearing
July 11, 2025) (Bloom, C.M.J.), R&R granted
adopted, 2025 WL 2112074 (M.D.
Pa. July 28, 2025) (Munley, J.).
|| Baptista v. Lowe, No. 1:23-CV- 19 months Weighs in Bond
|| 1666, 2024 WL 3410600, at *2 favor of relief | hearing
|| (M.D. Pa. Apr. 30, 2024) (Bloom, granted
C.M.J.), R&R adopted, No. 1:23-CV-
|| 01666, 2024 WL 3410587 (M.D. Pa.
|| May 7, 2024) (Mannion, J.).
| Elyardo v. Lechleitner, No. 1:23-CV- | 19 months Weighs in Bond
01089, 2023 WL 8259252, at *2 favor of relief | hearing
| (M.D. Pa. Nov. 29, 2023) (Kane, J.). granted
Appiah v. Lowe, No. 3:24-CV-2222, | 18 months Does not Bond
2025 WL 510974, at *4 (M.D. Pa. weigh in favor | hearing
Feb. 14, 2025) (Mariani, J.). of relief denied
Malede v. Lowe, No. 1:22-CV- 18 months Weighs in Bond
|} 01031, 2022 WL 3084304, at *6 favor of relief | hearing
|| (M.D. Pa. Aug. 3, 2022) (Schwab, granted

Clarke v. Doll, No. 3:20-CV-00031, 18 months Weighs in Bond
2020 WL 4983215, at *4 (M.D. Pa. favor of relief | hearing
June 3, 2020) (Saporito, M.J.), R&R granted
adopted, 481 F. Supp. 3d 394 (M.D.
Pa. 2020) (Conner, J.), app.
dismissed, No. 20-3162, 2021 WL
1740271, at *1 (3d Cir. Jan. 13,
2021).
Santana-Rivas v. Warden of Clinton | 15 months Weighs in Bond
Cnty. Corr. Facility, No. 3:25-CV- favor of relief | hearing
01896, 2025 WL 3522932, at *11 granted
(M.D. Pa. Nov. 13, 2025) (Camoni,
M.J), R&R adopted in part, rejected
in part on other grounds, 2025 WL
3513152 (M.D. Pa. Dec. 8, 2025)
(Wilson, J).
White v. Lowe, No. 1:23-CV-1045, 15 months Does not Bond
2023 WL 6305790, at *2 (M.D. Pa. weigh in favor | hearing
Sept. 27, 2023), rev'd and of relief denied
remanded sub nom. White v.
Warden Pike Cnty. Corr. Facility,
No. 23-2872, 2024 WL 4164269 (3d
Cir. Sept. 12, 2024) (detention had
reached 27 months).
Saint Jacques v. Dep't of Homeland | 14 months Does not Bond
Sec., No. 1:21-CV-1144, 2021 WL weigh in favor | hearing
4494623, at *2 (M.D. Pa. Sept. 30, of relief denied
2021) (Mariani, J.).
Ibrahim v. Superintendent of Miami | 13 months Neutral factor | Bond
Corr. Facility, No. 1:25-CV-00727, hearing
2026 WL 116489, at *4 (M.D. Pa. granted
Jan. 15, 2026) (Wilson, J).
McDougall v. Warden, Pike Cnty. 13 months Does not Bond
Corr. Facility, No. 3:23-CV-759, weigh in favor | hearing
2023 WL 6161038, at *2 (M.D. Pa. of relief denied
Sept. 21, 2023) (Mariani, J.).
Shapovalov v. Immigr. & Customs 9 months Does not Bond
Enft Agency, No. 1:21-CV-0900, weigh in favor | hearing
2021 WL 3128747, at *3 (M.D. Pa. of relief denied
July 23, 2021) (Wilson, J.).

Sydykov v. Immigr. & Customs Enft, | 9 months Does not Bond
No. 1:21-CV-00575, 2021 WL weigh in favor | hearing
2222732, at *2 (M.D. Pa. June 2, of relief denied
2021) (Wilson, J.).
Acevedo v. Decker, No. 1:20-CV- 9 months Does not Bond
01679, 2021 WL 120473, at *4 weigh in favor | hearing
(M.D. Pa. Jan. 13, 2021) (Wilson, of relief denied
J.).
Barradas-Jacome v. Lowe, No. 8 months Does not Bond
1:21-CV-1885, 2022 WL 256299, at weigh in favor | hearing
*3 (M.D. Pa. Jan. 26, 2022) of relief denied
(Conner, J.).
Baghdad v. Doll, No. 1:21-CV-293, 8 months Does not Bond
2021 WL 1391784, at *6 (M.D. Pa. weigh in favor | hearing
Apr. 13, 2021) (Rambo, J.) of relief denied
Ema v. Wilkinson, No. 1:21-CV- 7 months Does not Bond
00172, 2021 WL 3878289, at *5 weigh in favor | hearing
(M.D. Pa. Mar. 17, 2021) (Schwab, of relief denied
M.J.), R&R adopted, 2021 WL
3871300 (M.D. Pa. Aug. 30, 2021)
(Mariani, J.)
Salau v. Hoover, No. 3:25-CV- 2 months Does not Bond
02295, 2026 WL 49557, at *4 (M.D. weigh in favor | hearing
Pa. Jan. 7, 2026) (Mehalchick, J). of relief denied

Ndungu v. Doll, No. 4:20-CV-2268, 1 month Does not Bond
2021 WL 1916700, at *5 (M.D. Pa. weigh in favor | hearing
Apr. 9, 2021) (Arbuckle, J.), R&R of relief denied
adopted, 2021 WL 1910083 (M.D.
Pa. May 12, 2021) (Mariani, J.)

2Q

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11251155. Public record. Not legal advice.