Ayala Gonzalez v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
ANGEL AYALA GONZALEZ,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-1123
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 a writ of habeas corpus pursuant to 28 U.S.C. § 2241.
(Pet., ECF No. 1.) For the following reasons, the Court will conditionally grant Petitioner’s petition
for a writ of habeas corpus pursuant to 28 U.S.C. § 2241.
Discussion
I. 	Procedural History
In Petitioner’s § 2241 petition, Petitioner challenges the lawfulness of his current detention
and asks the Court to, inter alia, issue a writ of habeas corpus pursuant to 28 U.S.C. § 2241 either
ordering Respondents to release Petitioner or ordering Respondents to conduct a bond hearing to
satisfy the requirements of due process. (Pet., ECF No. 1, PageID.22–24.)
In an order entered on April 7, 2026, the Court directed Respondents to show cause, within
three business days, why the writ of habeas corpus and other relief requested by Petitioner should
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not be granted. (Order, ECF No. 3.) Respondents filed their response on April 10, 2026, (ECF
No. 4), and Petitioner filed his reply on April 15, 2026, (ECF No. 5).
II. 	Factual Background
Petitioner is a native and citizen of Mexico. (Notice to Appear (NTA), ECF No. 4-2,
PageID.71.) Petitioner attempted to enter the United States on February 27, 2001, and was
encountered by Department of Homeland Security (DHS) agents near Hereford, Arizona. (Form
I-213, ECF No. 4-1, PageID.68.) At that time, Petitioner voluntarily returned to Mexico. (Id.)
Petitioner entered the United States in or around March 2001 at an unknown location
without inspection. (NTA, ECF No. 4-2, PageID.71; Resp., ECF No. 4, PageID.30; Pet., ECF
No. 1, PageID.9.) After Petitioner entered the United States, DHS agents encountered Petitioner
and, subsequently, DHS issued Petitioner a 	Form 	I-862, NTA, 	charging Petitioner with
inadmissibility under § 212(a)(6)(A)(i) of the Immigration and Nationality Act (INA) because
Petitioner is an immigrant “present in the United States without being admitted or paroled, or who
arrived in the United States at any time or place other than as designated by the Attorney General.”
(NTA, ECF No. 4-2, PageID.71; Form I-213, ECF No. 4-1, PageID.68.) Petitioner was then
released into the United States on his own recognizance. (Form I-213, ECF No. 4-1, PageID.68.)
On November 12, 2025, ICE agents encountered and arrested Petitioner. 1 (Form I-213,
ECF No. 4-1, PageID.68.) Petitioner was scheduled for a master calendar hearing on April 15,
1 Respondents indicate that Petitioner was the target of an enforcement operation. (Form I-213,
ECF No. 4-1, PageID.68.) Respondents do not argue that Petitioner is subject to mandatory
detention pursuant to 8 U.S.C. § 1226(c), and there is nothing in the record presently before the
Court to suggest that Petitioner was a law enforcement target for any reason other than his status
as a noncitizen. (See id.)
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2026, in the Detroit Immigration Court. 2 (Notice of Internet-Based Hearing, ECF No. 4-4,
PageID.75.)
III. 	Habeas Corpus Legal Standard
The Constitution guarantees that the writ of habeas corpus is “available to every individual
detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) (citing U.S.
Const., Art I, § 9, cl. 2). Section 2241 of Title 28 confers the federal courts with the power to issue
writs of habeas corpus to persons “in custody in violation of the Constitution or laws or treaties of
the United States.” 28 U.S.C. § 2241. This includes challenges by non-citizens in immigration-
related matters. See Zadvydas v. Davis, 533 U.S. 678, 687 (2001); see also A. A. R. P. v. Trump,
145 S. Ct. 1364, 1367 (2025).
IV. 	Exhaustion
Respondents argue that the Court should deny Petitioner’s request for habeas corpus relief
because Petitioner has not exhausted his administrative remedies. Specifically, Respondents argue
that Petitioner should pursue a bond hearing and, if necessary, appeal any unfavorable decision to
the Board of Immigration Appeals.
The Court declines to enforce the doctrine of prudential exhaustion against Petitioner, and
even if the Court were to conclude that exhaustion is warranted, the Court concludes in the
alternative that waiver of exhaustion is appropriate, for the reasons set forth in the Court’s
exhaustion analysis in each of the following cases: Antele Cobix v. Raycraft, No. 1:25-cv-1669,
2025 WL 3562651, at *2–3 (W.D. Mich. Dec. 12, 2025); Candela Bastidas v. Noem, No. 1:25-cv-
1528, 2025 WL 3562638, at *2–4 (W.D. Mich. Dec. 12, 2025); Acuna Sanchez v. Noem, No. 1:25-
2 The parties do not provide any other information about the April 15, 2026, hearing.
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cv-1442, 2025 WL 3562577, at *2–4 (W.D. Mich. Dec. 12, 2025); Penagos Robles v. U.S. Dep’t
of Homeland Sec., No. 1:25-cv-1578, 2025 WL 3558128, at *2–3 (W.D. Mich. Dec. 12, 2025).
Accordingly, the Court will proceed to address the merits of Petitioner’s § 2241 petition.
V. 	Merits Discussion
A. 	Statutory Basis for Petitioner’s Detention
Petitioner contends that Respondents have violated the INA by concluding that Petitioner
is detained pursuant to the mandatory detention provisions set forth in 8 U.S.C. § 1225(b)(2).
Respondents, 	however, 	contend 	that 	Petitioner 	meets 	every 	element 	for 	detention 	under
§ 1225(b)(2), and that the statute’s structure and history support Respondents’ interpretation.
The Court concludes that § 1226(a), not § 1225(b)(2)(A), governs noncitizens, such as
Petitioner, who have resided in the United States and were already within the United States when
apprehended and arrested for the reasons set forth in the Court’s statutory analysis in each of the
following cases: Antele Cobix v. Raycraft, No. 1:25-cv-1669, 2025 WL 3562651, at *3–6 (W.D.
Mich. Dec. 12, 2025); Candela Bastidas v. Noem, No. 1:25-cv-1528, 2025 WL 3562638, at *4–6
(W.D. Mich. Dec. 12, 2025); Acuna Sanchez v. Noem, No. 1:25-cv-1442, 2025 WL 3562577,
at *4–7 (W.D. Mich. Dec. 12, 2025); Penagos Robles v. U.S. Dep’t of Homeland Sec., No. 1:25-
cv-1578, 2025 WL 3558128, at *3–6 (W.D. Mich. Dec. 12, 2025). 3
B. 	Fifth Amendment Due Process Considerations
Petitioner also argues that his detention violates the Fifth Amendment’s Due Process
Clause. Respondents counter Petitioner’s arguments by stating that Petitioner has received notice
3 The Court is aware of Buenrostro-Mendez v. Bondi, 166 F.4th 494 (5th Cir. 2026), which was
recently issued by the United States Court of Appeals for the Fifth Circuit, and Avila v. Bondi,
No. 25-3248, --- F.4th ----, 2026 WL 819258 (8th Cir. Mar. 25, 2026), which was recently issued
by the United States Court of Appeals for the Eighth Circuit. At this time, these non-binding cases
do not change the Court’s analysis.
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of the charges against him, has access to counsel, may attend hearings with an immigration judge,
has the right to appeal the denial of any request for bond, and has been detained by ICE for a
relatively short period of time.
The Court concludes that Petitioner’s current detention under the mandatory detention
framework set forth in § 1225(b)(2)(A) violates Petitioner’s Fifth Amendment due process rights
for the reasons set forth in the Court’s constitutional analysis in each of the following cases:
Antele Cobix v. Raycraft, No. 1:25-cv-1669, 2025 WL 3562651, at *6–8 (W.D. Mich. Dec. 12,
2025); Candela Bastidas v. Noem, No. 1:25-cv-1528, 2025 WL 3562638, at *7–8 (W.D. Mich.
Dec. 12, 2025); Acuna Sanchez v. Noem, No. 1:25-cv-1442, 2025 WL 3562577, at *7–9 (W.D.
Mich. Dec. 12, 2025); Penagos Robles v. U.S. Dep’t of Homeland Sec., No. 1:25-cv-1578, 2025
WL 3558128, at *6–8 (W.D. Mich. Dec. 12, 2025).
VI. 	Other Claims and Other Forms of Relief
Because the Court will conditionally grant Petitioner’s § 2241 petition as set forth herein,
the Court does not address other claims and other requested relief in Petitioner’s § 2241 petition.
VII. 	Proper Respondents
Respondents argue that the Detroit ICE Field Office Director is the only proper Respondent
in this action, and they seek the dismissal of all of the other named Respondents. The Court
concludes that the ICE Detroit Field Office Director is not the only proper Respondent for the
reasons set forth in the Court’s analysis of the same argument in each of the following cases:
Antele Cobix v. Raycraft, No. 1:25-cv-1669, 2025 WL 3562651, at *8–9 (W.D. Mich. Dec. 12,
2025); Candela Bastidas v. Noem, No. 1:25-cv-1528, 2025 WL 3562638, at *8–9 (W.D. Mich.
Dec. 12, 2025); Acuna Sanchez v. Noem, No. 1:25-cv-1442, 2025 WL 3562577, at *9–10 (W.D.
Mich. Dec. 12, 2025); Penagos Robles v. U.S. Dep’t of Homeland Sec., No. 1:25-cv-1578, 2025
WL 3558128, at *9–10 (W.D. Mich. Dec. 12, 2025).
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To ensure that this Court’s orders regarding a hearing or release will bind at least one
Respondent with authority to act in the event that Petitioner is transferred out of the Western
District of Michigan, the Court will retain the ICE Detroit Field Office Director and the Secretary
for the Department of Homeland Security as Respondents. The Court will dismiss the Department
of Homeland Security and the United States Attorney General as Respondents.
Conclusion
For the reasons discussed above, the Court will enter a judgment conditionally granting
Petitioner’s petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. (ECF No. 1.) The
Court will order Respondents to provide Petitioner with a bond hearing under 8 U.S.C. § 1226(a)
within five business days of the date of this Court’s opinion and judgment with notice to the Parties
as soon as practicable, no later than 24 hours prior to the scheduled hearing, or, in the alternative,
immediately release Petitioner from custody. 4 The Court will also order Respondents to file a
status report within six business days of the date of this Court’s opinion and judgment to certify
compliance with this opinion and the corresponding judgment. The status report shall include if
and when the bond hearing occurred, if bond was granted or denied, and if bond was granted, the
conditions of the bond, or if bond was denied, the reasons for the denial. Further, the Court will
dismiss the Department of Homeland Security and the United States Attorney General as
Respondents.
Dated:
Jane M. Beckering
United States District Judge
4 This Court has adopted a standard practice of requiring such a hearing within five business days,
even if the Petitioner requests a deadline that is shorter or longer or only release.
April 30, 2026 	/s/ Jane M. Beckering
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