Contreras-Zambrano v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
JESUS ALEJANDRO CONTRERAS-
ZAMBRANO,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-802
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 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.
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 or
provide Petitioner with a bond hearing where the government bears the burden of proof by clear
and convincing evidence that Petitioner is a flight risk or danger to the community. (Pet., ECF
No. 1, PageID.11.)
In an Order entered on March 13, 2026, the Court directed Respondents to show cause,
within three business days, why the writ of habeas corpus and other relief requested by Petitioner
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should not be granted. (Order, ECF No. 4.) Respondents filed their response on March 18, 2026
(ECF No. 5), and Petitioner filed his reply later on March 23, 2026 (ECF No. 6).
II. 	Relevant Factual Background
Petitioner is a citizen of Venezuela entered the United States as a minor child on April 26,
2023. Op., Contreras-Zambrano v. Raycraft, (Contreras-Zambrano I), No. 1:26-cv-332 (Mar. 4,
2026, W.D. Mich.) (ECF No. 7); (Pet., ECF No. 1, PageID.5.) On December 27, 2025, ICE agents
arrested Petitioner when he attended a scheduled ICE check-in appointment just shortly after his
18th birthday. Op., Contreras-Zambrano I, No. 1:26-cv-332; (Pet., ECF No. 1, PageID.5.)
On January 29, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without 	a 	bond 	hearing 	in 	Contreras-Zambrano 	I. 	In 	Contreras-Zambrano 	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., Contreras-Zambrano I, No. 1:26-cv-332
(ECF Nos. 7, 8.)
On March 10, 2026, Petitioner received a bond hearing pursuant to § 1226(a). (Pet., ECF
No. 1, PageID.5.) At the conclusion of the January 27, 2026, hearing, in a written order, the
Immigration Judge denied Petitioner’s request for bond, stating:
The Court finds that the Department of Homeland Security has proven by a
preponderance of the evidence, and even at the higher standard of clear and
convincing evidence, that the Respondent is a flight risk and there are no conditions
or combination of conditions that would reasonably assure the Respondent’s future
appearances at immigration proceedings.
(Immigration Judge Order, ECF No. 1-1, PageID.15.)
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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 March 10,
2026. Specifically, Petitioner argues that the Immigration Judge failed to require the government
to demonstrate dangerousness or flight risk by clear and convincing evidence. See Soto-Medina v.
Lynch, No. 1:25-cv-1704, --- F. Supp. 3d ----, 2026 WL 161002, at *2 (W.D. Mich. Jan. 21, 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.
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: 	March 25, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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