Rinko v. Raycraft, et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
ZAKIR HOSSAIN RINKO ,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondent.
____________________________/
Case No. 1:26-cv-1265
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, Petitioner challenges the lawfulness of his current detention
and asks the Court to, inter alia, issue a writ of habeas corpus pursuant to 28 U.S.C. § 2241
ordering Respondents to immediately release Petitioner. (Pet., ECF No. 1, PageID.21.)
In an Order entered on April 23, 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. 4.) Respondents filed their response on April 28, 2026,
(ECF No. 6), and a recording of the February 6, 2026, bond hearing on April 28, 2026. (Recording
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of Feb. 67, 2026, Bond Hearing, filed on Apr. 28, 2026.) On the same day, Petitioner filed his
reply (ECF No. 6).
II. 	Factual Background
Petitioner is a native and citizen of Bangladesh. (Pet., ECF No. 1, PageID.8.)
On January 13, 2026, Petitioner filed a § 2241 petition challenging his initial detention
without a bond hearing in Rinko v. Raycraft (Rinko I), No. 1:26-cv-121 (W.D. Mich.). In Rinko 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. & J., Rinko I, (W.D. Mich. Feb. 2,
2026), (ECF Nos. 6, 7.).
On February 6, 2026, Petitioner received a bond hearing pursuant to § 1226(a). (Order
Immigration Judge, ECF No. 1-2, PageID.25.) On that same day, the immigration judge issued an
order denying bond. (Id.) The Order of the Immigration Judge specifically states:
Denied because[:]
[Petitioner] did not establish he is not a flight risk. {Petitioner] recently entered the
U.S. illegally on October 15, 2024. [Petitioner] presents with limited community
ties, and no known family or property ties to the U.S. The length and nature of
[Petitioner’s] relationship with his listed sponsor is unknown beyond that the
sponsor is a friend. Thus, the Court has concerns with the reliability of the sponsor.
Matter of Dobrotvorskii, 29 I&N Dec. 211 (BIA 2025). Upon review, [Petitioner’s]
Form I-589 remains speculative, especially since [Petitioner’s] asylum case would
appear to be subject to the Circumvention of Lawful Pathways Bar. Thus, it’s not
clear there is a probable path for [Petitioner] to remain in the U.S. See Matter of R-
A-V-P-, 27 I&N Dec. 803 (BIA 2020).
(Id.)
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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.
V. 	Proper Respondents
Respondents argue that the Detroit ICE Field Office Director is the only proper Respondent
in this action. They seek the dismissal 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 habeas relief
will bind at least one Respondent with authority to act in the event that Petitioner is transferred
outside the area under the authority of the ICE Detroit Field Office, the Court will retain all of the
remaining Respondents.
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Conclusion
For the reasons discussed above, the Court will enter a Judgment conditionally granting
Petitioner’s petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. (ECF No. 1.) The
Court will order Respondent 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
Respondent 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.
Dated: 	June 8, 2026 	/s/ Jane M. Beckering
Jane M. Beckering
United States District Judge
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