Janikulov v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
NURBEK JANIKULOV,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-787
Honorable Jane M. Beckering
OPINION
Petitioner, a United States Immigration and Customs Enforcement (ICE) detainee currently
detained at the North Lake Processing Center located in Baldwin, Lake County, Michigan, initiated
this action by filing a counseled petition for writ of habeas corpus pursuant to 28 U.S.C. § 2241.
(Pet., ECF No. 1.) For the following reasons, the Court will deny Petitioner’s petition for a writ of
habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.
I. 	Procedural History
In Petitioner’s § 2241 petition, Petitioner challenges the constitutionality of his current
detention following an order issued by the Detroit Immigration Court denying him bond, and asks
the Court to, inter alia, issue a writ of habeas corpus ordering Respondents to release Petitioner or
provide Petitioner with a bond hearing where the government bears the burden of proof by clear
and convincing evidence that Petitioner is a flight risk or danger to the community. (Pet., ECF
No. 1, PageID.9.)
In an order entered on March 16, 2026, the Court directed Respondents to show cause,
within three business days, why the writ of habeas corpus and other relief requested by Petitioner
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should not be granted. (Order, ECF No. 4.) Respondents filed their response and a recording of the
March 3, 2026, bond hearing on March 19, 2026. (Resp., ECF No. 5; Recording of Mar. 3, 2026,
Bond Hearing, filed on Mar. 19, 2026.) Petitioner filed his reply on March 21, 2026, (ECF No. 6.).
II. 	Relevant Factual Background
Petitioner is a citizen of Uzbekistan who entered the United States in 2023. (Pet., ECF
No. 1, PageID.3.) On January 13, 2026, Petitioner was arrested by ICE. (Id., PageID.4–5.)
On February 12, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Janikulov v. The GEO Group et al. (Janikulov I), No. 1:25-cv-477 (W.D.
Mich.). In Janikulov I, the Court conditionally granted Petitioner’s petition for a writ of habeas
corpus pursuant to 28 U.S.C. § 2241, ordering Respondents to provide Petitioner with a bond
hearing under 8 U.S.C. § 1226(a) within five business days of the date of the Court’s Opinion and
Judgment or, in the alternative, immediately release Petitioner from custody. Op. & Jud.,
Janikulov I, (W.D. Mich. Feb. 26, 2026), (ECF Nos. 7, 8.).
On March 3, 2026, Petitioner received a bond hearing pursuant to § 1226(a). (Pet., ECF
No. 1, PageID.5.) At that hearing, Petitioner argued that he was not a danger to the community or
a flight risk because he had no criminal record, was employed as a commercial truck driver, owned
a trucking business, paid his income taxes, attended all scheduled immigration court hearings, and
obtained an immigration sponsor. (Id., PageID.5; Recording of Mar. 3, 2026, Bond Hearing, filed
on Mar. 19. 2026.) Respondents argued that Petitioner was a flight risk as he hid under a blanket
in the sleeper of the truck when authorities tried to question him. (Recording of Mar. 3, 2026, Bond
Hearing, filed on Mar. 19. 2026.) At the conclusion of the March 3, 2026, hearing, in a written
order, the Immigration Judge denied Petitioner’s request for bond, stating:
Denied, because: Flight risk. Respondent has been in the United States for a short
period of time and has limited familial ties. Per the I-213, during a traffic stop,
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Respondent hid from authorities under a blanket in the sleeper of a truck when
authorities attempted to question him.
(Immigration Judge Order, ECF No. 1-12, PageID.59.)
III. 	Discussion
In Petitioner’s § 2241 petition, Petitioner argues that the Immigration Judge did not apply
the constitutionally required burden of proof at Petitioner’s § 1226(a) bond hearing on March 3,
2026. Specifically, Petitioner argues that the Immigration Judge failed to require the government
to demonstrate dangerousness or flight risk by clear and convincing evidence. See Soto-Medina v.
Lynch, No. 1:25-cv-1704, --- F. Supp. 3d ----, 2026 WL 161002, at *2 (W.D. Mich. Jan. 21, 2026)
(addressing the constitutionally required burden of proof).
Based on the record before the Court at this time, including the recording of the § 1226(a)
bond hearing, there is no indication in the record that the Immigration Judge applied an
unconstitutional burden of proof at the bond hearing. Under these circumstances, the Court will
deny Petitioner’s § 2241 petition without prejudice.
Conclusion
For the reasons discussed above, the Court will enter a judgment denying Petitioner’s
petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.
Dated: 	April 15, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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