Lnu v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
VINOD LNU,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-1137
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. (Pet., ECF No. 1, PageID.20.) In an order entered on April 9, 2026, the Court
directed Respondents to show cause, within three business days, why the writ of habeas corpus
should not be granted. (Order, ECF No. 4.) Respondents filed their response and a recording of the
March 3, 2026, bond hearing on April 9, 2026, (Resp., ECF No. 5; Recording of Mar. 3, 2026,
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Bond Hearing, filed on Apr. 9, 2026), and Petitioner filed his reply on April 15, 2026, (ECF No.
6).
II. 	Factual Background
Petitioner is a citizen of India who entered the United States in 2024. Op., Lnu v. Raycraft
(Lnu I), No. 1:26-cv-457 (W.D. Mich. Feb. 25, 2026) (ECF No. 6). On November 24, 2025, ICE
agents arrested Petitioner. Id.
On February 10, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Lnu I. In Lnu 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., Lnu I, (W.D. Mich. Feb. 25, 2026), (ECF Nos. 6, 7).
On March 3, 2026, Petitioner received a bond hearing pursuant to § 1226(a). Immigration
Judge Order, Lnu I, (W.D. Mich. Mar. 5, 2026) (ECF No. 8-1). At the conclusion of that hearing,
the immigration judge denied Petitioner’s request for bond, concluding that Respondent had not
met his burden of “provid[ing] sufficient evidence” as follows:
Flight risk. Respondent has not provided sufficient evidence of a stable residence
or employment. Respondent has limited familial contacts in the United States and
limited contacts to the community. There is insufficient information as to the
likelihood of success on any applications for relief.
Id.
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
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v. Lynch, No. 1:25-cv-1704, --- F. Supp. 3d ----, 2026 WL 161002, at *2 (W.D. Mich. Jan. 21,
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.
V. 	Proper Respondents
Respondents argue that the Detroit ICE Field Office Director is the only proper Respondent
in this action, and they seek the dismissal of all of the other named Respondents. The Court
concludes that the ICE Detroit Field Office Director is not the only proper Respondent for the
reasons set forth in the Court’s analysis of the same argument in each of the following cases:
Antele Cobix v. Raycraft, No. 1:25-cv-1669, 2025 WL 3562651, at *8–9 (W.D. Mich. Dec. 12,
2025); Candela Bastidas v. Noem, No. 1:25-cv-1528, 2025 WL 3562638, at *8–9 (W.D. Mich.
Dec. 12, 2025); Acuna Sanchez v. Noem, No. 1:25-cv-1442, 2025 WL 3562577, at *9–10 (W.D.
Mich. Dec. 12, 2025); Penagos Robles v. U.S. Dep’t of Homeland Sec., No. 1:25-cv-1578, 2025
WL 3558128, at *9–10 (W.D. Mich. Dec. 12, 2025).
To ensure that this Court’s orders regarding a hearing or release will bind at least one
Respondent with authority to act in the event that Petitioner is transferred out of the Western
District of Michigan, the Court will retain the ICE Detroit Field Office Director and the Secretary
for the Department of Homeland Security as Respondents. The Court will dismiss the United States
Department of Homeland Security, the United States Attorney General, and the Executive Office
for Immigration Review as Respondents.
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Conclusion
The Court will order Respondents to provide Petitioner with an individualized bond
hearing before a neutral 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
denied, and if bond was granted, the conditions of the bond, or if bond was denied, the reasons for
the denial. Further, the Court will dismiss the United States Department of Homeland Security,
the United States Attorney General, and the Executive Office for Immigration Review as
Respondents.
Dated:
Jane M. Beckering
United States District Judge
/s/ Jane M. Beckering	April 21, 2026
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