Karovaliya v. Bondi et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
IMRANALI AHMADBHAI
KAROVALIYA,
Petitioner,
VS.
PAMELA JO BONDI, et al.,
Respondents.
§
§
§
§
§
§ 	CIVIL ACTION NO. 4:26-CV-00346
§
§
§
§
ORDER OF DISMISSAL
The petitioner, Imranali Ahmadbhai Karovaliya, is a detainee in the custody of
United States Department of Homeland Security, Immigration and Customs Enforcement
("ICE") officials. 	Through counsel, petitioner filed a petition for a writ of habeas corpus
under 28 U.S.C. § 2241 , challenging his continued detention. Doc. No. 1.
While this case was pending, the Fifth Circuit decided Buenrostro-Mendez v. Bondi,
--- F.4th ----, No. 25-20496, 2026 WL 323330 (5th Cir. Feb. 6, 2026). 	The Court may
dismiss a habeas petition on the pleadings "[i]f it plainly appears from the petition and any
attached exhibits that the petitioner is not entitled to relief." Rule 4 of the Rules Governing
§ 2254 Cases in the United States District Courts (authorizing preliminary review and
summary dismissal of habeas petitions on the pleadings). 1
1 A district court may apply any of the rules governing habeas petitions filed under 28 U.S.C.
§ 2254 to those filed under 28 U.S .C. § 2241. See Rule l(b), Rules Governing§ 2254 Cases in the
1 / 3
United States District Court
Southern District of Texas
ENTERED
February 24, 2026
Nathan Ochsner, Clerk
Case 4:26-cv-00346 Document 6 Filed 02/24/26 in TXSD Page 1 of 3

The petition and attached exhibits reflect that Petitioner is a noncitizen who entered
without inspection and has not been admitted to the United States. Doc. No. 1 at 4, 19 , 22.
Petitioner contends that he is entitled to a bond hearing under 8 U.S.C. § 1226(a), the statute
permitting discretionary bond, and that he has been erroneously categorized as a detainee
subject to mandatory detention under 8 U.S.C. § 1225(b)(2).
Petitioner's arguments regarding sections 1225 and 1226 and their implementing
regulations are foreclosed by Buenrostro-Mendez. 	Likewise, his arguments regarding the
class action in Maldonado Bautista v. Santacruz, --- F.Supp.3d ----, 2025 WL 3713987
(C.D. Cal. Dec. 18, 2025), fail because they are based on an interpretation of sections 1225
and 1226 that was rejected by the Fifth Circuit in Buenrostro-Mendez. 	See Maldonado
Bautista, 2025 WL 3713987, at *8-12.
In addition, Petitioner's Fifth Amendment Due Process Clause claims are precluded,
at this juncture, by Demore v. Kim, 538 U.S. 510,531 (2003), because "[d]etention during
removal proceedings is a constitutionally permissible part of that process." Id. ( citations
omitted); see also Jennings v. Rodriquez, 583 U.S. 281, 297 (2018) (explaining that
"§§1225(b)(l) and 1225(b)(2) thus mandate detention of applicants for admission until
certain proceedings have concluded").
Accordingly, the Court ORDERS as follows:
1. 	The petition (Doc. No. 1) is DENIED.
2. 	This case is DISMISSED without prejudice.
United States District Courts.
2/3
Case 4:26-cv-00346 Document 6 Filed 02/24/26 in TXSD Page 2 of 3

3/3
3. All other pending motions, if any, are DENIED as MOOT.
4. If the Fifth Circuit, en bane, or the United States Supreme Court enters a decision
that is contrary to the decision in Buenrostro-Mendez v. Bondi, supra, Petitioner
is granted leave to file a motion for reconsideration or initiate a separate petition.
SO ORDERED.
Signed: February 24, 2026
Andrew S. Hanen
United States District Judge
Case 4:26-cv-00346 Document 6 Filed 02/24/26 in TXSD Page 3 of 3