# Luis

> District Court, M.D. Pennsylvania · May 19, 2026

URL: https://www.frixlaw.com/law-library/cases/11358486

## Case

- **Full name:** Angela Luis v. John Eh. Rife, in his official capacity as acting Philadelphia Field Office Director for U.S. Immigration and Customs Enforcement, et al.
- **Court:** District Court, M.D. Pennsylvania
- **Decided:** May 19, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF PENNSYLVANIA
ANGELA LUIS, A241 738 630,
Petitioner, CIVIL ACTION NO. 3:26-cv-00834
v. (SAPORITO, J.)
JOHN EH. RIFE, in his official
capacity as acting Philadelphia
Field Office Director for U.S.
Immigration and Customs
Enforcement, et al.,
Respondents.
MEMORANDUM
On April 1, 2026, the petitioner, appearing through counsel, filed a

petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. Doc. 1.

In this petition, Angela Luis, a native and citizen of the Dominican
Republic, challenges the legality of her pre-removal-order immigration
detention without an individualized bond hearing. At the time of filing,
Luis was being held in the custody of United States Immigration and

Customs Enforcement (“ICE”) at an ICE Enforcement and Removal
Operations (“ERO”) sub-office, located in York County, Pennsylvania.
I. BACKGROUND AND PROCEDURAL HISTORY
Luis initially entered the United States without inspection at or

near San Luis, Arizona, on or about July 24, 2022. Luis was apprehended
by Customs and Border Patrol shortly thereafter and detained briefly.
That same day, she was released on her own recognizance, pursuant to 8
U.S.C. § 1226(a).! See Pet. Ex. B, Doc. 1-3. At the time of her release, Luis

was served with a Notice to Appear, DHS Form I-862, dated July 24,
2022, which declared her to be subject to removal as an “alien present in
the United States who has not been admitted or paroled,”? and which
directed her to appear for a hearing before an immigration judge in
Philadelphia, Pennsylvania, on August 3, 2023. Pet. Ex. A, Doc. 1-2;
Resp. Ex. 2, Doc. 4°38.
After her entry into the United States in July 2022, Luis settled in

in Lancaster, Pennsylvania, where she was residing before being
incarcerated. Luis has applied for asylum and for withholding of removal,

1 At the time of her initial release, Luis was served with an Order
of Release on Recognizance, DHS Form 1-220A, dated July 24, 2022, and
prepared by an immigration officer, which advised that she had been
released on her own recognizance pursuant to “section 236 of the
Immigration and Nationality Act and the applicable provisions of Title 8
of the Code of Federal Regulations.” Pet. Ex. B, Doc. 1-3. The Order of
Release on Recognizance further directed her to report in person to the
York ERO sub-office on September 27, 2022. Id.
2 Notably, a box on the Notice for declaring her to be an “arriving
alien” was not checked. Pet. Ex. A, Doc. 1-2; Resp. Ex. 2, Doc. 4-3.

= 9 -

but her asylum application has not yet been adjudicated. Prior to her
arrest and detention, Luis was gainfully self-employed as a cleaner.
On or about November 10, 2025, Luis was issued a citation for
misdemeanor driving under the influence and related traffic offenses.
Luis apparently missed a court date, so a bench warrant was issued for
her arrest. On or about March 28, 2026, Luis was pulled over for a routine
traffic stop and arrested pursuant to the bench warrant. On March 30,
2026, Luis posted bail in connection with these state criminal
proceedings, but she remained in custody pursuant to an immigration
detainer.
On April 1, 2026, immigration authorities arrested Luis on the
detainer and took her into custody at Lancaster County Prison. She was
transported to the York ERO sub-office for processing, and she was later
transported to ICE’s El Paso Processing Service Center in Texas, where
she remains in civil immigration detention. She has been denied any
opportunity to post bond or to be released on other conditions.
II. DISCUSSION
Since the United States began restricting
immigration into this country in the late 19th century,
it has distinguished between those noncitizens seeking
entry into the country and those already residing

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within it. Noncitizens “stopped at the boundary line”
who have “gained no foothold in the United States” do
not enjoy the same constitutional protections afforded
to persons inside the United States. But once a
noncitizen enters the United States, “the legal
circumstance changes,” for the constitutional right to
due process applies to all “persons” within our nation’s
borders, “whether their presence here is lawful,
unlawful, temporary, or permanent.” This distinction
between noncitizens who have entered and reside in
the United States and those who have not yet entered
“runs throughout immigration law.”
Quijada Cordoba v. Knight, 809 F. Supp. 8d 1113 (D. Idaho 2025) (first
quoting Kaplan v. Tod, 267 U.S. 228, 280 (1925); and then quoting
Zadvydas v. Davis, 533 U.S. 678, 698 (2001)) (citations omitted).
Consistent with this distinction, “[thwo statutory sections govern
the detention of noncitizens prior to a final order of removal: 8 U.S.C,
§ 1225 and 1226.” Lepe v. Andrews, 801 F. Supp. 3d 1104, 1111 (E.D. Cal.
Sept. 28, 2025), appeal filed, No. 25-7429 (9th Cir. Nov. 25, 2025). As
concisely summarized by the Supreme Court: “U.S. immigration law
authorizes the Government to detain certain aliens seeking admission
into the country under §§ 1225(b)(1) and (b)(2). It also authorizes the
Government to detain certain aliens already in the country pending the
outcome of removal proceedings under §§ 1226(a) and (c).” Jennings v.
Rodriguez, 583 U.S. 281, 289 (2018) (emphasis added).

- 4 .

Under § 1225, “an alien who ‘arrives in the United States,’ or ‘is
present’ in this country but ‘has not been admitted, is treated as an
‘applicant for admission.” Jennings, 583 U.S. at 287 (quoting 8 U.S.C.
§ 1225(a)(1)). Applicants for admission may be detained pending removal
under two separate provisions: § 1225(b)(1) and § 1225(b)(2).
Section 1225(b)(1) applies to aliens who (A) are arriving in the
United States, see § 1225(b)(1)(A)@ (the “arriving aliens provision”), or
have been physically present in the United States for less than two years
without being admitted or paroled, see § 1225(b)(1)(A)Gii) (the
“designation provision”),3 and (8) are inadmissible either for
misrepresenting a material fact while attempting to gain admission to

3 This so-called “designation provision” further limits this group of
aliens subject to expedited removal proceedings to certain categories of
aliens expressly designated by the Secretary of Homeland Security, see
§ 1225(b)(1)(a) Gi), but the current scope of that designation is “the full
scope of statutory authority,” and thus all aliens who have not been
admitted or paroled into the United States and who have not been
physically present in the United States continuously for the two-year
period prior to determination of inadmissibility are subject to expedited
removal under § 1225(b)(1). See Designating Aliens for Expedited
Removal, 90 Fed. Reg. 8139 (Jan. 24, 2025); see also Make the Rd. N.Y. v.
Wolf 962 F.3d 612, 619-20 (D.C. Cir. 2020) (providing a historic overview
of groups designated under § 1225(b)(1)(a)Gi))} Coal for Humane
Immigrant Rts. v. Noem, 805 F. Supp. 3d 48, 62-64 (D.D.C. 2025) (same),
appeal filed, No. 25-5289 (D.C. Cir. Aug. 11, 2025).

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the United States or for lacking proper immigration documentation. See
8 U.S.C. § 1225(b)(1)(A); see also § 1182(a)(6)(C) (inadmissibility based

on misrepresentation); § 1182(a)(7) Gnadmissibility for lack of
documentation). For these aliens, § 1225(b)(1) provides for expedited
removal proceedings without further hearing or review, unless the alien

expresses a fear of persecution or an intent to apply for asylum, in which

case the alien is subject to mandatory detention pending a final
determination of credible fear of persecution and, if found not to have
such a fear, until removal. See § 1225(b)(1)(B). See generally Make the
Rd. N.Y. v. Wolf 962 F.8d 612, 618-20 (D.C. Cir. 2020) (summarizing
expedited removal provisions); Rodriguez-Acurio v. Almodovar, 811 F.
Supp. 3d 274, 291-92 (E.D.N.Y. 2025) (same); Coal. for Humane
Immigrant Rts. v. Noem, 805 F. Supp. 3d 48, 59-64 (D.D.C. 2025) (same),
appeal filed, No. 25-5289 (D.C. Cir. Aug. 11, 2025).
Section 1225(b)(2) is a “broader... catchall provision” that applies
to other “applicants for admission” who are “seeking admission” to the
United States.4 See 8 U.S.C. § 1225(b)(2)(A); Jennings, 583 U.S. at 287.

4 The statute expressly provides that § 1225(b)(2) does not apply to
those to whom § 1225(b)(1) applies, as well as other categories not
relevant here. See 8 U.S.C. § 1225(b)(2){B).

-6-

Under § 1225(b)(2), an applicant for admission is placed into ordinary
(not expedited) removal proceedings. See § 1225(b)(2)(A); see also id.
§ 1229a (describing ordinary removal proceedings before an immigration
judge). With limited exceptions, however, an alien is subject to mandatory
detention under § 1225(b)(2) while removal proceedings remain pending.
See § 1225(b)(2)(A); see also § 1182(d)(5) (authorizing the Secretary of
Homeland Security to grant humanitarian parole to aliens awaiting
removal proceedings); § 1225(b)(2(C) (providing that aliens arriving on
land from a foreign territory contiguous to the United States may be
returned to that foreign territory pending removal proceedings, rather
than be detained); Quijada Cordoba, 809 F. Supp. 3d at 1113 (Section
1225(b) mandates detention without bond hearings, except for narrow
humanitarian parole.”).
Meanwhile, as noted above, § 1226 “authorizes the Government to
detain certain aliens already in the country pending the outcome of
removal proceedings.” Jennings, 583 U.S. at 289. Such aliens who are
already present in the United States may be detained pending removal
under two separate provisions: § 1226(a) and § 1226(c).
Section 1226(a) prescribes a discretionary detention framework for

7.

these aliens when subject to removal proceedings, providing that: “On a

warrant issued by the Attorney General,! an alien may be arrested and
detained pending a decision on whether the alien is to be removed from
the United States.” 8 U.S.C. § 1226(a). The statute further provides that
such an alien may be released on bond while removal proceedings remain
pending. Jd. § 1226(a)(2). The relevant implementing regulations provide
that a § 1226(a) detainee may be released on bond upon showing “that
such release would not pose a danger to property or persons, and that the
alien is likely to appear for any future proceeding.” 8 C.ER. §§ 236.1(c)(8),
1236.1(c)(8). Immigration authorities® are tasked with an initial bond or
custody determination, see id. §§ 236.1(c)(8), 1236.1(c)(8), after which the
alien may request an individualized bond hearing before an immigration
judge, see 7d. §§ 236.1(d)(1), 1236.1(d)(1); see also § 1003.19 (setting out
procedures for the review of bond determinations by immigration judges).
See generally Nielsen v. Preap, 586 U.S, 392, 397 (2019) (“If the alien is

This statutory authority to issue immigration arrest warrants has
been delegated to a number of supervisory immigration officials listed in
the applicable regulations. See 8 C.FR. § 287.5(e)(2); see also id.
§§ 236.1(b), 1236.1(b).
6 The same supervisory immigration officials authorized to issue
arrest warrants. See 8 C.FR. §§ 236.1(c)(8), 1236.1(c)(8).

-g-

detained, he may seek review of his detention by an officer at the
Department of Homeland Security and then by an immigration judge
(both exercising power delegated by the Secretary); and the alien may
secure his release if he can convince the officer or immigration judge that
he poses no flight risk and no danger to the community.”) (citations
omitted). An adverse bond determination by the immigration judge can
be appealed to the Board of Immigration Appeals. See 8 U.S.C.
§§ 236.1(d)(3), 1286.1(d)(3). See generally Borbot v. Warden Hudson Cnty.
Corr. Facility, 906 F.3d 274, 275 (8d Cir. 2018) (summarizing § 1226(a)
bond procedures).
Finally, “Section 1226(c)... carves out a statutory category of
aliens who may not be released under § 1226(a).” Jennings, 583 U.S. at
289. This subsection specifies certain criminal histories that require
mandatory detention of aliens who would otherwise be eligible for a bond
hearing under § 1226(a). See 8 U.S.C. § 1226(c). Such criminal aliens may
only be released under very narrow circumstances involving a
determination by the Attorney General that the ahen’s release is

necessary for witness-protection purposes and the alien does not pose a
flight risk or a danger to the community. See id. § 1226(c)(4); see also

-Q-

Jennings, 583 U.S. at 289.
The petitioner in this case, Angela Luis, has been detained by
immigration authorities without a bond determination pending
disposition of her ordinary, § 1229a removal proceedings.’ In her petition,
Luis argues that, because she was detained within the interior of the
United States, she is not properly subject to mandatory pre-removal-
order detention under § 1225(b)(2). Rather, she contends that he may
only be properly detained under § 1226(a), which requires that she be
given an opportunity for an individualized bond hearing, Luis further
asserts two claims under the Administrative Procedures Act (“APA”):
(a) a claim that the agency has failed to follow its own bond regulations;
and (b) a claim that application of § 1225(b)(2) and its mandatory
detention policy to her, an alien who has been residing in the United

parties appear to agree that the petitioner has been putatively
detained without an opportunity for a bond determination pursuant to
§ 1225(b)(2). The respondent has identified no other basis for her
detention. Moreover, the petitioner has not been placed in expedited
removal proceedings, as would be expected for a § 1225(b)(1) detainee,
she lacks the criminal record to qualify her for mandatory detention
under § 1226(c), and immigration officials have refused to give her a bond
hearing, as required under § 1226(a).

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States since 2022, was arbitrary and capricious.® In addition to these
statutory arguments, Luis argues that her pre-removal detention
without an opportunity to be considered for release on bond violates her
Fifth Amendment procedural and substantive due process rights.9
The respondent, on the other hand, argues that § 1225(b)(2) does
properly apply to the petitioner, and that it prescribes mandatory
detention.!° The respondent further argues that applying § 1225(b)(2)
here comports with due process, 1!
The respondent purports to have detained Luis pursuant to 8
U.S.C. § 1225(b)(2), which provides for mandatory detention without the
opportunity for release on bond. The petitioner, however, contends that
she could only be properly detained under 8 U.S.C. § 1226(a), and under

8 Having granted relief on the basis of the petitioner’s primary
statutory claim—that her detention is pursuant to § 1226(a) rather than
§ 1225(b)(2)—-we decline to reach the petitioner’s alternative arguments
that her detention violates the APA.
9 Having found a statutory basis for relief, we do not reach the
constitutional issues raised by the petitioner as alternative grounds for
relief. See generally Lyng v. Nw. Indian Cemetery Protective Ass'n, 485
U.S. 489, 445 (1988) (‘A fundamental and longstanding principle of
judicial restraint requires that courts avoid reaching constitutional
questions in advance of the necessity of defending them.”).
10 We note that the respondent's answer does not engage with the
petitioner’s APA claim at all. In any event, see supra note 8.
11 See supra note 9.

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that statute, she is entitled to an individualized bond hearing.
“(Flor section 1225(b)(2)(A) to apply, several conditions must be
met—in particular, an ‘examining immigration officer’ must determine
that the individual is: () an ‘applicant for admission’; (2) ‘seeking
admission’; and (8) ‘not clearly and beyond a doubt entitled to be
admitted.” Martinez v. Hyde, 792 F. Supp. 3d 211, 214 (D. Mass. 2025)
(quoting 8 U.S.C. § 1225(b)(2)(A)), appeal dismissed, No. 25-1902 (1st Cir.
Dec. 23, 2025); see also Kashranov, 2025 WL 3188399, at *6 (citing
Martinez); Ramirez-Montoya v. Rose, No. 3:25-CV-02411, 2025 WL
3709045, at *4 (M.D. Pa. Dec. 22, 2025) (citing Martinez and Kashranov):
Carrero Romero v. Lowe, No. 4:26-CV-00009, 2026 WL 296215, at *4
(M.D. Pa. Feb. 4, 2026) (citing Ramirez-Montoya). Significantly, “Section
1225(b)(2)(A) applies only to an alien who is both an applicant for
admission and ‘seeking admission.” Kashranov, 2025 WL 3188899, at *6
(emphasis in original); see also Ramirez-Montoya, 2025 WL 3709045, at
*4 (citing Kashranov and Bethancourt Soto v, Soto, 807 F. Supp. 3d 897,
406 (D.N.J. 2025); Carrero Romero, 2026 WI. 296215, at *4 (quoting
Ramirez-Montoya).
Section 1225 defines an “applicant for admission” as “laln alien

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present in the United States who has not been admitted or who arrives
in the United States.” 8 U.S.C. § 1225(a)(1). Meanwhile, the phrase
“seeking admission” is not defined in § 1225, and the courts of this circuit
have construed the plain language of “seeking admission” to describe
“active and ongoing conduct—physically attempting to come into the
United States, typically at a border or a port of entry.” Kashranov, 2025
WL 3188399, at *6; see also Ramirez-Montoya, 2025 WL 3709045, at *4
(citing Kashranov); Carrero Romero, 2026 WL 296215, at *4 (citing
Ramirez-Montoya). “This reading preserves the distinction between
‘seeking admission’ and the separate term ‘applicant for admission,’
ensuring that each phrase carries independent meaning.” Kashranov,
2025 WL 3188399, at *6; see also Ramirez-Montoya, 2025 WL 3709045,
at *4 (quoting Kashranov); Carrero Romero, 2026 WL 296215, at *4
(quoting Ramirez-Montoya). It also comports with the Supreme Court’s
finding in Jennings that “§ 1225(b) applies primarily to aliens seeking
entry into the United States.” Jennings, 583 U.S. at 297; Ramirez-
Montoya, 2025 WL 3709045, at *4 (quoting Jennings); Carrero Romero,
2026 WL 296215, at *4 (quoting Jennings and Ramirez-Montoya). “In

sum, a plain reading of § 1225(b) demonstrates that it applies to

individuals who are attempting to enter the United States, not those
already within the country.” Carrero Romero, 2026 WL 296215, at *4; see
also Kashranov, 2025 WL 3188399, at *7 (considering the statutory
context of § 1225(b)(2) and concluding that this provision “contemplates
inspection and detention at or immediately following border crossing”).
By contrast, as the Supreme Court has previously recognized,
“§ 1226 applies to aliens already present in the United States.” Jennings,
583 U.S. at 303; see also Carrero Romero, 2026 WL 296215, at *4 (quoting
Jennings). “Section 1226(a) creates a default rule for those aliens by
permitting—but not requiring—the Attorney General to issue warrants
for their arrest and detention pending removal proceedings,” and it
“permits the Attorney General to release those aliens on bond.” Jennings,
583 U.S. at 303; see also Carrero Romero, 2026 WL 296215, at *4 (quoting
Jennings); Ramirez-Montoya, 2025 WL 38709045, at *5 (Unlike
§ 1225(b)(2)(A), § 1226(a) provides for bond or conditional parole.”) (citing
8 U.S.C. § 1226(a)(2)). “[U]nder Section 1226(a) and its implementing
regulations, [an alien discretionarily detained pending removal
proceedings] is entitled to a bond hearing before an Immigration Judge
at which the government must prove by clear and convincing evidence

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that he poses a danger to the communityl] or... that he is a flight risk,
if it seeks to continue detaining him.” Gomes v. Hyde, 804 F. Supp. 3d
265, 277 (D. Mass. 2025);12 see also YZ. v, Soto, 812 F. Supp. 3d 459, 462-
63 (D.N.J. 2025) (“Noncitizens who are arrested after having lived in the
United States for a while do not generally have to be detained. They are
instead entitled to a bond hearing before an immigration court.” (citing
Gomes) (citations and footnote omitted)), See generally Carrero Romero,
2026 WL 296215, at *4 (“[I]f an individual is detained attempting to enter
the country illegally or while otherwise presenting themselves for
inspection and entry, they are subject to mandatory detention pursuant

12 We note that, applying First Circuit precedent, the Gomes court
stated that the government may prove that an alien is a danger to the
community by clear and convincing evidence, or that he is a flight risk by
the lesser preponderance-of-the-evidence standard. See Gomes, 804 F.
Supp. 3d at 277 (citing Hernandez-Lara v. Lyons, 10 F.4th 19, 41 (1st Cir.
2021)). The Third Circuit, however, has held that the government must
prove either dangerousness or flight risk by clear and convincing
evidence. See German Santos v. Warden, 965 F.3d 208, 213-14 (8d Cir.
2020) (“When the Government seeks to take more than just money from
a party, we typically hold the Government to a standard of proof higher
than a preponderance of the evidence.”); see also Gayle v. Warden
Monmouth Cnty, Corr. Inst., 12 F.4th 321, 333 n.9 (8d Cir. 2021) (“Lt is
a ‘settled rule that when a party stands to lose his liberty, even
temporarily, we hold the Government to a ‘clear and convincing evidence’
standard in the context of civil detention... .”) (quoting German Santos);
Luciano-Jimenez v. Doll, 547 F. Supp. 3d 462, 465 (M.D. Pa. 2021)
(quoting German Santos).

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to § 1225. If they are arrested after having already entered the country,
they are subject to detention under § 1226 and are entitled to a bond
hearing.”).
Here, § 1226(a), not § 1225(b)(2)(A), applies to the detention of Luis.
We find that Luis is no longer seeking admission into the United States—
at the time of her arrest and detention, she was not actively attempting
to come into the United States at a border or port of entry. Rather, she is
already here, having resided within the United States for an extended
period of time. See Kashranov, 2025 WL 3188399, at *1 (finding that
petitioner who lived in the United States for almost two years was not
“seeking admission” but “already here”); Ramirez-Montoya, 2025 WL
3709045, at *5 (citing Kashranov). Thus, Luis may only be properly
detained pursuant to § 1226(a), and therefore she is entitled to a bond
hearing. See Carrero Romero, 2026 WL 296215, at *5. See generally Luis

v. O'Neill, No. 3:25-cv-2185, 2025 WL 3516865, at *4 (M.D. Pa. Dec. 8,
2025) (‘The overwhelming majority of federal district courts that have
addressed this issue have interpreted the INA to find that persons
similarly situated to Petitioner—noncitizens who previously entered the
United States and are currently residing in the United States—are not

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subject to the mandatory detention provision of 8 U.S.C. § 1225(b)(2)(A)
but instead are subject to the discretionary detention pursuant to 8
U.S.C. § 1226(a) and accordingly are entitled to a bond hearing.”); id. at
*4 & n.7 (collecting Third Circuit district court cases).13
III. CONCLUSION
For the foregoing reasons, the court concludes that the petitioner is
currently detained pursuant to 8 U.S.C. § 1226(a), not 8 U.S.C.

13 Accord Barbosa da Cunha v. Freden, _. F.4th , 2026 WL
1146044, at *5, 6 (2d Cir. Apr. 28, 2026) (“Section 1226(a) plainly applies
to noncitizens, like Petitioner, who are present in the United States, but
charged as inadmissible for entering the country without inspection and
admission.... Section 1225(b)(2)(A) applies to those noncitizens who
present themselves at a port of entry for admission, or who cross the
physical border into the United States but are apprehended at the
‘threshold of initial entry.”); Castafion-Nava v. U.S. Dep’t of Homeland
Sec, __ F4th , 2026 WL 1223250, at *21 (7th Cir. May 5, 2026)
(“[Tlhe text, statutory context, legislative history, and long-standing
Executive practice all confirm that § 1225(b)(2)(A) applies to ‘applicants
for admission’ who are seeking lawful entry at the border or ports of entry
and not to noncitizens unlawfully living in the country’s interior.”);
Hernandez Alvarez v. Warden, __. F. 4th , 2026 WL 12438395, at *1
(11th Cir. May, 6, 2026) (‘The text and statutory structure of the INA,
bolstered by the long history of detention across our immigration laws
and the congressional purpose in passing IJRIRA, yield the conclusion
that no-bond detention generally apples to arriving aliens seeking lawful
entry to the country, and not to aliens who are simply present here.”):
Lopez-Campos v. Raycraft, _. F.4th , at *11, 2026 WL 1283891 (6th
Cir. May 11, 2026) (holding that noncitizens without lawful status who
had lived in the United States for years were not “seeking admission” and
thus were not subject to § 1225(b)(2)(A)’s mandatory detention scheme).

-47.-

§ 1225(b){2), and thus she is entitled to an individualized bond hearing.
Accordingly, the petition will be granted, and the government will be
ordered to provide the petitioner with an individualized bond hearing
within twenty-one days or to release her from custody.
An appropriate order follows.

Dated: May _! g , 2026 5 fF :
SEPH F. SAPORITONIR.
United States District Judge

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11358486. Public record. Not legal advice.
