Ahmed v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
SALMAN AHMED,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-1828
Honorable Jane M. Beckering
OPINION
Petitioner, a United States Immigration and Customs Enforcement (ICE) detainee, initiated
this action by filing a 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, he 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 pursuant to 28 U.S.C. § 2241 ordering Respondents to
release Petitioner. (Pet., ECF No. 1, PageID.24.) In an Order entered on June 12, 2026, the Court
directed Respondents to show cause, within three business days, why the writ of habeas corpus
should not be granted. (Order, ECF No. 3.) Respondents filed their response on June 17, 2026.
(Resp., ECF No. 4.)
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II. 	Factual Background
Petitioner is a native and citizen of Bangladesh who entered the United States in late 2022.
Op., Salman Ahmed v. Kristi Noem (Ahmed I), No. 1:26-cv-183 (W.D. Mich Feb. 18, 2026) (ECF
No. 7). On January 7, 2026, Petitioner was arrested by ICE agents. Id.
On January 16, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Ahmed I. In Ahmed 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., Ahmed I, (W.D. Mich. Jan. 20, 2. Feb. 18, 2026), (ECF Nos. 7, 8).
On February 24, 2026, Petitioner received a bond hearing pursuant to § 1226(a). Status
Report, Ahmed I, (W.D. Mich. Feb. 26, 2026 (ECF No. 9-1). At the conclusion of that hearing, the
immigration judge denied Petitioner’s request for bond, explaining in a written order:
Respondent unlawfully entered the United States and has remained without
authorization. While the Respondent has filed an application for asylum, the
application has not been submitted to this Court for purposes of the bond hearing
and any relief is speculative. Respondent has been in the United States for a short
period of time. Respondent has not presented sufficient evidence to this Court
regarding employment within the United States. Respondent has failed to provide
tax returns despite his presence in the United States since 2022. Respondent does
not have parents or siblings with legal status in the United States.
In addition, Respondent has failed to comply with the terms of his prior release
under the Alternatives to Detention release program.
The Court finds that Respondent is a flight risk and therefore denies his request for
bond reconsideration.
Id.
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III. 	Analysis
Respondents argue that the Court should deny Petitioner’s § 2241 petition due to a lack of
jurisdiction and Petitioner’s failure to exhaust Petitioner’s administrative remedies, as well as on
the merits. The Court has fully addressed these issues and Respondents’ arguments in Soto-Medina
v. Lynch, 817 F. Supp. 3d 612 (W.D. Mich. 2026). Therefore, for the reasons set forth in Soto-
Medina, the Court will conditionally grant Petitioner’s petition for a writ of habeas corpus pursuant
to 28 U.S.C. § 2241.
IV. 	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.
V. 	Proper Respondents
Respondents argue that the Detroit ICE Field Office Director is the only proper Respondent
in this action. They seek the dismissal 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). To ensure that this Court’s orders regarding habeas relief
will bind at least one Respondent with authority to act in the event that Petitioner is transferred
outside the area under the authority of the ICE Detroit Field Office, the Court will retain all of the
remaining Respondents.
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Conclusion
The Court will order Respondents to provide Petitioner with an individualized bond
hearing before an immigration judge, at which time the government will have the burden to
demonstrate dangerousness or flight risk by clear and convincing evidence, within five business
days and 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. 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.
Dated: 	June 23, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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