Daniel Raygoza Vasquez, a Mexican national living in Burley, Idaho with his fiancee and infant child — both U.S. citizens — was taken into ICE custody on or about April 2, 2026, after an immigration detainer was lodged while he was in jail. The government detained him under § 1225, which mandates detention without a bond hearing for noncitizens deemed applicants for admission. Raygoza had previously been removed to Mexico in July 2022, returned later that year, and, according to his petition, had been living and working in Idaho since. He filed a habeas petition on April 1, 2026.
The core dispute tracks a policy shift that began in July 2025, when ICE issued interim guidance directing that all persons who entered the United States without inspection be subject to mandatory detention under § 1225(b)(2)(A), regardless of how long they had resided in the country. The Board of Immigration Appeals followed in September 2025 with a precedential decision, Matter of Yajure Hurtado, 29 I. & N. Dec. 216 (BIA 2025), holding that immigration judges lack authority to conduct bond hearings for such individuals. District courts across the country have since been presented with habeas petitions challenging that interpretation.
Judge B. Lynn Winmill of the District of Idaho, who described having resolved dozens of substantively identical petitions in recent months, held again that Raygoza's detention is governed by § 1226 rather than § 1225. The government urged reconsideration in light of Buenrostro-Mendez v. DHS, 166 F.4th 494 (5th Cir. 2026), and Avila v. Bondi, No. 25-3248, 2026 WL 819258 (8th Cir. Mar. 25, 2026), both of which sided with the government's position. Winmill declined, stating the court was not persuaded by the reasoning in those decisions and was instead persuaded by the reasoning reflected in the dissents in those cases and by the Seventh Circuit's decision in Castanon-Nava v. U.S. Department of Homeland Security, 161 F.4th 1048 (7th Cir. 2025), issued in the preliminary injunction context.
The remedy question was more complicated than in prior cases. Raygoza had failed to appear for past court hearings related to a driving-without-privileges citation and had been convicted of providing false information to law enforcement following a February 10, 2026 traffic stop in which he gave a false name and date of birth. During the same stop, he was also charged with possession of a controlled substance and possession of drug paraphernalia; those charges were later dismissed. The government argued those facts were indicia of danger to the community and flight risk. The court agreed that an individualized bond hearing — rather than outright release — was the appropriate remedy. The order required respondents to either release Raygoza or provide him with a bond hearing before his April 16, 2026 removal hearing; if that hearing was continued, the bond hearing was to be held before the continued immigration hearing or within seven days of the April 15 order, whichever occurred first.
The ruling deepens an existing circuit split. The Fifth and Eighth Circuits have endorsed the government's broad reading of § 1225, while the Seventh Circuit, in the preliminary injunction context, has rejected it. District courts in Idaho, New York, Massachusetts, and elsewhere have repeatedly ruled against the government's position.