Maldonado-Calderon v. Raycraft et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
______
ADONIER MALDONADO-CALDERON,
Petitioner,
v.
KEVIN RAYCRAFT et al.,
Respondents.
____________________________/
Case No. 1:26-cv-1640
Honorable Hala Y. Jarbou
OPINION
Petitioner, a United States Immigration and Customs Enforcement (ICE) detainee, initiated
this action by filing a 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 dismiss Petitioner’s petition for a writ of habeas
corpus pursuant to 28 U.S.C. § 2241 without prejudice.
Discussion
I. 	Procedural History
The habeas petition challenges the lawfulness of Petitioner’s 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 release Petitioner. (Pet., ECF No. 1, PageID.7.)
In an order entered on May 22, 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. 3.) Respondents filed their response on May 28, 2026, (ECF
No. 4.)
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II. 	Relevant Factual Background
Petitioner is a native and citizen of Honduras. (Pet., ECF No. 1, PageID.3.) Petitioner
entered the United States in 2022 and has remained in the United States since that time. (Form I-
213, ECF No. 4-1, PageID.21.) In May 2025, ICE detained Petitioner. (Pet., ECF No. 1, PageID.4.)
On June 4, 2025, an immigration judge (IJ) released Petitioner on a $7,500 bond. (Order, ECF
No. 4-3, PageID.29.) Petitioner was arrested for an alcohol-related driving offense on December
26, 2025, and at that time, ICE issued a warrant for Petitioner’s arrest. (Orange Cnty. Incarcerations
Document, ECF No. 4-4, Page.ID.32, 33; DHS Warrant, ECF No. 4-5, PageID.35.) Thereafter,
ICE took Petitioner into custody (see Dec. 2025, Form I-213, ECF No. 4-1), and on January 23,
2026, ICE cancelled Petitioner’s immigration bond. (Notice, ECF No. 4-7, PageID.44.)
During a second § 1226 bond hearing held on April 29, 2026, the IJ with the Detroit
Immigration Court denied Petitioner’s bond request. (Apr. 29, 2026, Order of the IJ, ECF No. 4-
9, PageID.53.) In a written order, the IJ concluded he did not have “authority to hear bond requests
or to grant bond to aliens who are present in the United States without admission” under 8 U.S.C.
§ 1225(b)(2)(A). (Id.) Further, in the written order, the IJ also concluded that “[e]ven if the Court
had the jurisdiction or authority to consider [Petitioner’s] bond request, [Petitioner] has failed to
meet his burden of demonstrating [he] is not a danger to the community, and [Petitioner] has failed
to meet his burden of demonstrating [he] is not a flight risk.” (Id.)
III. 	Habeas Corpus Legal Standard
The Constitution guarantees that the writ of habeas corpus is “available to every individual
detained within the United States.” Hamdi v. Rumsfeld, 542 U.S. 507, 525 (2004) (citing U.S.
Const., Art I, § 9, cl. 2). Section 2241 of Title 28 confers the federal courts with the power to issue
writs of habeas corpus to persons “in custody in violation of the Constitution or laws or treaties of
the United States.” 28 U.S.C. § 2241. This includes challenges by non-citizens in immigration-
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related matters. See Zadvydas v. Davis, 533 U.S. 678, 687 (2001); see also A. A. R. P. v. Trump,
145 S. Ct. 1364, 1367 (2025).
“Under Article III of the United States Constitution, federal courts have the power to
adjudicate only ‘Cases’ and ‘Controversies.’” Cal. Palms Addiction Recovery Campus, Inc. v.
United States, 158 F.4th 726, 730 (6th Cir. 2025) (quoting Mokdad v. Sessions, 876 F.3d 167, 169
(6th Cir. 2017)). “Part of what Article III requires is that there be a live case or controversy—
‘when the issues presented are no longer live or the parties lack a legally cognizable interest in the
outcome,’ a case becomes moot.” Id. (some internal quotations omitted) (citation omitted). “When
the 	case-and-controversy 	requirement 	is 	not 	satisfied, 	federal 	courts 	lack 	subject-matter
jurisdiction.” Id. (citing Mokdad, 876 F.3d at 170.)
IV. 	Analysis
Noncitizens who are held in custody under 8 U.S.C. § 1226(a), while their petitions for
review of their removal orders are pending, are entitled to a bond hearing before an immigration
judge.1 Lopez-Campos v. Raycraft, Nos. 25-1965, 1969, 1978, 1982, 2026 WL 1283891 (6th Cir.
May 11, 2026). Before initiating this action, after Petitioner’s first bond was cancelled in January
2026, Petitioner had a § 1226 bond hearing in the Detroit Immigration Court, and the IJ issued a
written decision denying Petitioner’s request for bond on April 26, 2026. (Apr. 26, 2026, Order of
the IJ, ECF No. 4-9.) In the IJ’s written decision, the IJ concluded, inter alia, that “[e]ven if the
Court had the jurisdiction or authority to consider [Petitioner’s] bond request, [Petitioner] has
failed to meet his burden of demonstrating [he] is not a danger to the community, and [Petitioner]
has failed to meet his burden of demonstrating [he] is not a flight risk.” (Id.)
1 Respondents concede that § 1226 governs Petitioner’s detention. (Resp., ECF No. 4, PageID.15.)
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Although in the present § 2241 petition, Petitioner argues that his detention generally
violates the Due Process Clause of the Fifth Amendment, Petitioner does not raise any
constitutional claims regarding the April 2026 bond hearing. (See generally Pet., ECF No. 1.)
Indeed, Petitioner’s § 2241 petition does not mention the April 2026 bond hearing. (See id.) Under
these circumstances, because Petitioner received a bond hearing, and Petitioner does not raise any
claims regarding the bond hearing itself in the present action, the Court will dismiss the action
without prejudice as moot. 2
Conclusion
For the reasons discussed above, the Court will enter a judgment dismissing the petition
for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 without prejudice.
Dated: June 8, 2026 	/s/ Hala Y. Jarbou
HALA Y. JARBOU
CHIEF UNITED STATES DISTRICT JUDGE
2 Petitioner is free to challenge the nature of the bond hearing; however, any such challenge raises
new claims that were not raised in Petitioner’s original § 2241 petition and which are not presently
before the Court. If Petitioner wishes to file a new § 2241 petition raising claims regarding the
April 2026 bond hearing, Petitioner may do so by filing a new action with the applicable filing fee
or an application to proceed in forma pauperis.
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