DORANZIL

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA

Claude Doranzil, )

)

Petitioner, )

) Civil No. 26-894

v. )

)

US ICE, et. al., )

Respondents. )

OPINION

Pending before the court is a pro se motion filed by petitioner Claude Doranzil

(“Petitioner” or “Doranzil”)to enforce the court’s order1 that Petitioner receive an individualized

bond hearing, with attachments (ECF No. 11). The government filed a response in opposition to

the motion (ECF No. 16) and a supplemental response which attached a transcript of the hearing

(ECF No. 17). The motion is ripe for decision.

In the motion to enforce, Petitioner, a citizen of Haiti, admits that he received a bond

hearing, but argues that the hearing did not result in an individualized determination and failed to

comply with the court’s June 2, 2026 order. In essence, Petitioner argues that the immigration

judge made up her mind that Petitioner was a flight risk because he was subject to a removal

order and refused to consider his alternative arguments. Petitioner asserts that his detention is

unduly prolonged because he is not a flight risk or danger to the community and he appealed the

removal order. Respondents submitted a transcript of the bond hearing, which the court

reviewed (ECF No. 17).

1 The court issued an opinion, order and judgment on June 2, 2026, which granted in part the habeas

petition (ECF No. 1), and directed a bond hearing to be held within 10 days of its order (ECF Nos. 6, 7,

8). Respondents filed a notice that a bond hearing was held on June 11, 2026 (ECF No. 10).

Respondents argue the motion to enforce should be denied. They contend: (1) Doranzil

should have appealed the adverse bond decision by the immigration judge to the Board of

Immigration Appeals; and (2) the record confirms that he had a bond hearing that was

fundamentally fair and satisfies due process.

Federal courts “lack jurisdiction to review any discretionary determinations underlying

the [immigration judge’s] bond decision,” and may only “review whether the bond hearing was

fundamentally unfair” such that it violates the detainee’s due process rights. Ghanem v. Warden

Essex Cnty. Corr. Facility, No. 21-1908, 2022 WL 574624, at *2 (3d Cir. Feb. 25, 2022); see

Quinteros v. Warden Pike Cnty. Corr. Facility, 784 F. App’x 75, 78 (3d Cir. 2019) (“Because we

lack jurisdiction to review any discretionary determinations underlying the [immigration judge’s]

bond decision, we are limited to reviewing only those of [Appellant’s] challenges that pertain to

the adequacy of process he received at his bond hearing.”).

The United States Court of Appeals for the Third Circuit has advised that a bond hearing

under 8 U.S.C. § 1226 is “fundamentally fair,” and thus satisfies due process, if three essential

elements are present: (1) factfinding based on a record produced before the decisionmaker and

disclosed to the detainee; (2) the detainee is allowed to make arguments on his or her behalf; and

(3) the immigration judge makes an individualized determination of the detainee’s interests.

Ghanem, 2022 WL 574624 at *2; see also Quinteros, 784 F. App’x at 78. This court’s review of

the bond hearing is limited to considering whether the hearing was fundamentally fair under

Ghanem.

The court reviewed the unofficial transcript of the June 11, 2026 bond hearing. The

record reflects that Petitioner did not have prior notice of the hearing and was not represented by

counsel, but ultimately decided to go forward with the hearing. A Creole interpreter was

provided and Doranzil made arguments on his own behalf. 2 The government attorney opposed

bond on the basis of flight risk because Petitioner was subject to a removal order, had no close

relatives in the United States, and was not employed or paying taxes.

The immigration judge agreed with the government’s arguments. The immigration judge

found that Doranzil recently entered the United States, had no family ties or work history, and he

was ordered removed after a full merits hearing denying his request for asylum. The

immigration judge concluded Doranzil did not have a viable path to remain in the United States

and that no amount of bond would prevent him being a flight risk. (ECF No. 17-1).

After reviewing the record, the court concludes the immigration judge made an

individualized determination. The immigration judge provided an oral explanation for the

decision on the record, which enabled this court to meaningfully review the decision. The

decision was based on flight risk. The immigration judge noted that Petitioner has been in the

United States for a short time, Petitioner had no close family members in the United States (other

than a brother-in-law), he was not employed and he had been ordered to be removed. The

immigration judge determined that the lack of any incentive to appear for his removal could not

be mitigated by a bond.

Those are individualized circumstances, which the immigration judge considered. The

immigration judge was not convinced by Doranzil’s arguments concerning flight risk. Petitioner

or this court may disagree with the immigration judge’s decision, but that disagreement is not

sufficient to show the hearing was fundamentally unfair. This court lacks jurisdiction to overturn

the immigration judge’s discretionary determination. Habibi v. Barr, 445 F. Supp.3d 990, 997

2 Whether to permit testimony is a discretionary decision for the immigration judge. See Jeddou v.

Warden of Delaney Hall Det. Ctr., No. 2:26-CV-01203, 2026 WL 1005052, at *2 (D.N.J. Apr. 14, 2026)

(denying habeas petition based on argument that immigration judge deprived Petitioner of an opportunity

to testify).

(S. D. Cal. 2020) (court lacks jurisdiction to review immigration judge’s discretionary

determination about flight risk).

In sum, the bond hearing had each of the essential elements of a fundamentally fair bond

hearing and complied with Petitioner’s due process rights. Under those circumstances, any other

arguments are beyond the scope of this court’s review.3 See Ghanem, 2022 WL 574624 at *2.

Conclusion

Because Petitioner received an individualized bond hearing, the motion to enforce court

order (ECF No. 11) will be denied.

An appropriate order follows.

Dated: July 23, 2026

BY THE COURT:

/s/ Joy Flowers Conti

Joy Flowers Conti

Senior United States District Court Judge

3 Doranzil’s argument that the length of his detention has become unreasonable, see Zadvydas v. Davis,

533 U.S. 678 (2001), is not within the scope of a motion to enforce the court’s order that he receive an

individualized bond hearing.