Mamatkulov v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
BEKZOD MAMATKULOV,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-2746
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 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 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.13–14.) In an order entered on October 5, 2026, the Court
directed Respondents to show cause, within three business days, why the writ of habeas corpus
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should not be granted. (Order, ECF No. 3.) Respondents filed their response and a recording of the
January 1, 2026 and April 2, 2026, bond hearings on October 8, 2026, (Resp., ECF No. 4;
Recording of Jan. 1, 2026 and Apr. 2, 2026, Bond Hearings, filed on Oct. 8, 2026), and Petitioner
filed his reply on October 14, 2026, (ECF No. 5).
II. 	Relevant Factual Background
Petitioner is a citizen of Uzbekistan who entered the United States in 2023. (Pet., ECF
No. 1, PageID.4.) On November 20, 2025, Petitioner was arrested by ICE at a scheduled ICE
check-in appointment. (Id.)
On January 2, 2026, Petitioner received a bond hearing pursuant to § 1226(a). (Id. at 1–2.)
At the conclusion of the January 2, 2026, hearing, the immigration judge denied Petitioner’s
request for bond because “Department of Homeland Security has shown by preponderance of the
evidence that the Respondent is a flight risk….” (Immigration Judge Order, ECF No. 4-1,
PageID.100.)
On April 2, 2026, Petitioner received a subsequent bond hearing based on changed
circumstances and additional evidence. (Pet., ECF No. 1, PageID.2.) At the conclusion of the April
2, 2026, hearing, the immigration judge denied Petitioner’s request for bond because “[b]ond was
previously determined. No material change in circumstances.” (Immigration Judge Order, ECF
No. 4-3, PageID.104.)1
1 On April 15, 2026, Petitioner filed a counseled § 2241 petition in this Court challenging only his
mandatory detention under § 1225, not the constitutionality of the bond hearings he had received,
in Mamatkulov v. Raycraft et al. (Mamatkulov I), No. 1:26-cv-1230 (W.D. Mich.). Specifically, in
Mamatkulov I, Petitioner, proceeding with counsel, “argue[d] [only] that Respondents [we]re
subjecting him to mandatory detention under § 1225,” and the “§ 2241 petition and reply d[id] not
mention either bond hearing.” Op., Mamatkulov I, (W.D. Mich. Apr. 28, 2026), (ECF No. 6,
PageID.119). In Mamatkulov I, the Court dismissed without prejudice Petitioner’s petition for a
writ of habeas corpus pursuant to 28 U.S.C. § 2241, as moot because Respondents had provided
Petitioner with a bond hearing pursuant to § 1226 and Petitioner did not challenge the
constitutionality of the bond hearings he had received. Op. & J., Mamatkulov I, (W.D. Mich. Apr.
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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.
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
28, 2026), (ECF Nos. 6, 7). The Court noted that Petitioner would be “free to challenge the
constitutionality of the bond hearing itself; however, any such challenge raises new claims that
were not raised in Petitioner’s original § 2241 petition.” Op., Mamatkulov I, (W.D. Mich. Apr. 28,
2026), (ECF No. 6, PageID.119 n.1).
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denied, and if bond was granted, the conditions of the bond, or if bond was denied, the reasons for
the denial.
Dated:
Jane M. Beckering
United States District Judge
October 16, 2026 	/s/ Jane M. Beckering
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