Canales Carias v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
RAFAEL CANALES CARIAS,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-898
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.38.)
In an order entered on March 23, 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
January 22, 2026, bond hearing on March 26, 2026. (Resp., ECF No. 5; Recording of Jan. 22,
2026, Bond Hearing, filed on Mar. 26, 2026.) Petitioner filed his reply on March 31, 2026,
(ECF No. 6).
II. 	Relevant Factual Background
Petitioner is a citizen of Honduras who entered the United States in 2018. (Pet., ECF No. 1,
PageID.8, 14.) On October 30, 2025, ICE arrested Petitioner. (Id., PageID.15.)
On December 15, 2025, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Canales Carias v. Raycraft (Canales Carias I), No. 1:25-cv-1790 (W.D.
Mich.). In Canales Carias 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.,
Canales Carias I, (W.D. Mich. Jan. 15, 2026), (ECF Nos. 6, 7.).
On January 22, 2026, Petitioner received a bond hearing pursuant to § 1226(a). (Pet., ECF
No. 1, PageID.16; Order of the Immigration Judge, ECF No. 1-5, PageID.233.) On that same day,
the immigration judge issued an order denying bond. (Order of the Immigration Judge, ECF
No. 1-5, PageID.233.) The Order of the Immigration Judge states:
Denied because flight risk. The respondent has already been removed and has a
pending appeal before the BIA.
(Id.)
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 January 22,
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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 a
constitutionally deficient burden of proof. 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:
Jane M. Beckering
United States District Judge
April 20, 2026 	/s/ Jane M. Beckering
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