Singh v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
JASPREET SINGH,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-630
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 dismiss Petitioner’s petition for a writ
of habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.
Discussion
I. 	Procedural History
In Petitioner’s § 2241 petition, Petitioner challenges the lawfulness of his current detention
and asks the Court to, inter alia, assume jurisdiction over this matter and 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.27–28.)
In an order entered on February 27, 2026, the Court directed Respondents to show cause,
within three business days, why the writ of habeas corpus and other relief requested by Petitioner
Case 1:26-cv-00630-JMB-RSK ECF No. 8, PageID.<pageID> Filed 03/25/26 Page 1
of 4

2
should not be granted. (Order, ECF No. 4.) Respondents filed their response on March 4, 2026,
(ECF No. 5), and Petitioner filed his reply on March 5, 2026, (ECF No. 6). On March 10, 2026,
Petitioner submitted a written notice to the Court stating that he had received a bond hearing on
March 5, 2026, and that the immigration judge denied bond to Petitioner. (Notice, ECF No. 7.)
II. 	Factual Background
Petitioner is a native and citizen of India. (Notice to Appear (NTA), ECF No. 5-1,
PageID.79.) Petitioner entered the United States on or about May 3, 2022, at or near San Luis,
Arizona, without inspection. (Id.) After Petitioner entered the United States, Department of
Homeland Security (DHS) agents encountered Petitioner, and at that time, 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.” (Id.) DHS then released Petitioner into the
United States on his own recognizance “[i]n accordance with section 236 of the [INA],” which is
codified at 8 U.S.C. § 1226. (Order Release Recognizance, ECF No. 5-3, PageID.87.)
On or about December 16, 2025, Petitioner was attempting to enter Canada when he was
returned to the United States by Canadian border patrol agents and arrested by United States DHS
agents. (Pet., ECF No. 1, PageID.6; Form I-213, ECF No. 5-2, PageID.84.) At that point, DHS
agents discovered that Petitioner had criminal charges for theft and racketeering, as well as a
warrant for failure to appear. (Form I-213, ECF No. 5-2, PageID.84-85.) Petitioner informed the
DHS agents that he wished to be returned to India. (Id., PageID.85.)
Case 1:26-cv-00630-JMB-RSK ECF No. 8, PageID.<pageID> Filed 03/25/26 Page 2
of 4

3
Petitioner was scheduled for a master calendar hearing on March 3, 2026, in the Detroit
Immigration Court.1 (Notice of Internet-Based Hearing, ECF No. 5-5.) On March 5, 2026,
Petitioner received a bond hearing, at which time the immigration judge denied Petitioner’s request
for bond “on the grounds that [Petitioner] is subject to mandatory detention under the Laken Riley
Act.”2 (Notice, ECF No. 7.)
III. 	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).
“Under Article III of the United States Constitution, federal courts have the power to
adjudicate only ‘Cases’ and ‘Controversies.’” Cal. Palms Addiction Recovery Campus, Inc. v.
United States, 158 F.4th 726, 730 (6th Cir. 2025) (quoting Mokdad v. Sessions, 876 F.3d 167, 169
(6th Cir. 2017)). “Part of what Article III requires is that there be a live case or controversy—
‘when the issues presented are no longer live or the parties lack a legally cognizable interest in the
outcome,’ a case becomes moot.” Id. (some internal quotations omitted) (citation omitted). “When
the 	case-and-controversy 	requirement 	is 	not 	satisfied, 	federal 	courts 	lack 	subject-matter
jurisdiction.” Id. (citing Mokdad, 876 F.3d at 170.)
1 The parties do not provide any other information about the March 3, 2026, hearing.
2 The parties do not provide any other information about the March 5, 2026, hearing.
Case 1:26-cv-00630-JMB-RSK ECF No. 8, PageID.<pageID> Filed 03/25/26 Page 3
of 4

4
IV. 	Discussion
In Petitioner’s § 2241 petition, as relief, Petitioner asks the Court to order Respondents to
conduct a bond hearing or, alternatively, to release Petitioner from custody. (Pet., ECF No. 1,
PageID.27–28.) 	Since 	initiating 	this 	action, 	Petitioner 	received 	a bond 	hearing, 	and 	the
immigration judge denied Petitioner’s request for bond. (Notice, ECF No. 7.)
Petitioner subsequently notified the Court that a bond hearing took place, but Petitioner did
not raise any constitutional claims regarding the March 2026 bond hearing. (Id.) Under these
circumstances, because Petitioner received a bond hearing, which is the relief that he seeks in his
§ 2241 petition, and Petitioner does not raise any claims regarding the bond hearing itself in the
present action, it appears that the present § 2241 petition is moot. Therefore, the Court will dismiss
the action without prejudice.3
Conclusion
For the reasons discussed above, the Court will enter a judgment dismissing Petitioner’s
petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.
Dated: 	March 25, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
3 Petitioner is free to challenge the nature of the bond hearing; however, any such challenge raises
new claims that were not raised in Petitioner’s original § 2241 petition and which are not presently
before the Court. If Petitioner wishes to file a new § 2241 petition raising claims regarding the
March 2026 bond hearing, Petitioner may do so by filing a new action with the applicable filing
fee or an application to proceed in forma pauperis.
Case 1:26-cv-00630-JMB-RSK ECF No. 8, PageID.<pageID> Filed 03/25/26 Page 4
of 4