Sultanov v. Unknown Party #1 et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
ALI SULTANOV,
Petitioner,
v.
UNKNOWN PARTY #1 et al.,
Respondents.
____________________________/
Case No. 1:26-cv-946
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 without prejudice.
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.6.) 1
1 With the petition, Petitioner filed a motion for immediate release or bond hearing (ECF No. 3)
and emergency motion to stay (ECF No. 5). As set forth herein, the Court will deny Petitioner’s
§ 2241 petition, which resolves the case. Therefore, Petitioner’s motions are moot.
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In an order entered on February 2, 2026, the Court directed Respondents to show cause,
within three business days, why the writ of habeas corpus and other relief requested by Petitioner
should not be granted. (Order, ECF No. 5.) Respondents filed their response on February 5, 2026,
(ECF No. 6), and Petitioner filed his reply later that same day, (ECF No. 7).
II. 	Relevant Factual Background
Petitioner is a citizen of Kyrgyzstan who entered the United States in 2023. (Pet., ECF
No. 1, PageID.1; Op., Sultanov v. Raycraft (Sultanov I), No. 1:26-cv-276 (W.D. Mich Feb. 17,
2026) (ECF No. 11). In September 2025, Petitioner was arrested by ICE agents. (Id., PageID.2.)
On January 26, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Sultanov I. Sultanov I, No. 1:26-cv-276 (W.D. Mich Jan. 26, 2026) In
Sultanov 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., Sultanov
I, No. 1:26-cv-276 (W.D. Mich Feb. 17, 2026) (ECF Nos. 11, 13).
On February 24, 2026, Petitioner received a bond hearing pursuant to § 1226(a).
(Immigration Judge Order, ECF No. 9-2, PageID.43.) At the conclusion of that hearing, in a written
order, the Immigration Judge denied Petitioner’s request for bond, stating: “Flight Risk.” (Id.)
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 February
24, 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
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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: 	April 3, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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