Ardon Leon v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
MENFIL OTONIEL ARDON LEON,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 2:26-cv-239
Honorable Jane M. Beckering
OPINION
Petitioner, a United States Immigration and Customs Enforcement (ICE) detainee, initiated
this action by filing a 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.
(Pet., ECF No. 1, PageID.9.)
In an order entered on October 1, 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 not be granted. (Order, ECF No. 4.) Respondents filed their response and a recording of the
September 29, 2026, bond hearing on October 6, 2026. (Resp., ECF No. 5; Recording of Sep. 29,
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2026, Bond Hearing, filed on Oct. 6, 2026.) Petitioner filed a reply on October 9, 2026.
(ECF No. 6.)
II. 	Relevant Factual Background
Petitioner is a citizen of Guatemala who entered the United States in 2013. (Pet., ECF
No. 1, PageID.2.) On July 16, 2026, Petitioner was arrested by ICE agents. (Id., PageID.3.)
On September 29, 2026, Petitioner received a bond hearing pursuant to § 1226(a).
(Immigration Judge Order, ECF No. 5-2, PageID.207.) At the conclusion of that hearing, in a
written order, the Immigration Judge denied Petitioner’s request for bond, stating: “flight risk.”
(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 September
29, 2026. See Soto-Medina v. Lynch, 817 F. Supp. 3d 612 (W.D. Mich. 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.
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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
October 14, 2026 	/s/ Jane M. Beckering
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