Saray Ruiz Linares entered the United States on February 14, 2022, at Yuma, Arizona, at age sixteen, with her parents. Her family applied for asylum within a year of arrival, and she was granted employment authorization. She worked at Barrett Distribution for approximately a year, purchased and made timely payments on a vehicle titled in her name, maintained a driver's license listing her correct address, carried insurance, and attended New Life (Nueva Vida) Church in Memphis. She has no criminal history. On February 10, 2026, immigration authorities arrested her and transferred her to the West Tennessee Detention Facility in Mason, Tennessee, where she remained when she filed her habeas petition on February 27, 2026.
The legal fight turns on which of two statutes governs her detention. Section 1226(a) of the Immigration and Nationality Act allows immigration authorities to release a detained noncitizen on bond of at least $1,500 and entitles her to a hearing before an immigration judge. Section 1225(b)(2)(A) mandates detention without bond for "applicants for admission" who are "seeking admission." On July 8, 2025, ICE, in coordination with the Department of Justice, issued interim guidance reclassifying all undocumented immigrants — including those who had lived in the United States for years — as "applicants for admission," making mandatory no-bond detention the default for the entire population. The Board of Immigration Appeals adopted that interpretation in Yajure Hurtado, 29 I. & N. Dec. 216 (B.I.A. 2025).
Chief Judge Sheryl H. Lipman of the Western District of Tennessee held that the plain text of the two statutes does not support the government's position. The title of Section 1225 references "expedited removal of inadmissible arriving aliens," and Ruiz Linares was not arriving when she was detained far from the border after more than three years in the country. Applying Section 1225(b)(2)(A) to her would also render the phrase "seeking admission" superfluous — the record showed no determination by an immigration officer that she was not clearly and beyond a doubt entitled to be admitted. The court further held that the government's reading would make Section 1226(c) — which carves out mandatory detention for noncitizens with specified criminal histories — entirely pointless, because under ICE's theory all undocumented immigrants are already subject to mandatory detention regardless of criminal record. Courts must give effect to every clause and word of a statute, the court noted, citing Duncan v. Walker, 533 U.S. 167 (2001).
The court also pointed to Congress's 2025 passage of the Laken Riley Act, which added a new subsection to Section 1226(c) to preclude persons with certain criminal histories from receiving bond. That legislative action, the court reasoned, confirms that Congress understood Section 1226(a) to govern the general population of detained noncitizens — otherwise the amendment would have been pointless.
On due process, the court applied the Mathews v. Eldridge balancing test and held that Ruiz Linares's detention without a bond hearing violated the Fifth Amendment. Her strong liberty interest, the high risk of erroneous deprivation without an immigration judge evaluating flight risk and community danger, and her clean criminal record all weighed against the government. Because ICE detained her under the mandatory framework of Section 1225(b)(2)(A), which provides no bond-hearing mechanism, the court ordered immediate release rather than remanding for a bond hearing, consistent with its earlier decision in Godinez-Lopez v. Ladwig.
Respondent Christopher Bullock, Field Office Director of Enforcement and Removal Operations for the New Orleans Field Office, is enjoined from pursuing Ruiz Linares's detention under Section 1225(b)(2)(A) and was ordered to file a status report certifying compliance by April 22, 2026.