Marvin Roberto Ajqui Guzman, a Guatemalan citizen who has lived in the United States for several years without legal status, was arrested by Immigration and Customs Enforcement agents on March 20 and held at the Delaney Hall Detention Center. ICE detained Guzman under a mandatory detention provision that the agency argued applied to all individuals who entered the country without inspection, regardless of how long they had been in the U.S.
U.S. District Judge Brian R. Martinotti rejected the government's position, following his earlier ruling in Sandhu v. Tsoukaris that found the Department of Homeland Security's interpretation of the immigration statute was overly broad. "The Court rejected the contention ยง 1225(b)(2) provides the authority to mandatorily detain noncitizens who have resided within the United States for a considerable period simply because they were not admitted or paroled upon inspection at the border," Martinotti wrote, citing his November 2025 decision.
The case is part of a growing number of similar habeas corpus challenges in New Jersey federal court, where judges have repeatedly rejected the government's mandatory detention policy for long-term U.S. residents. The government had argued in a letter response that if the court found the mandatory detention statute didn't apply, Guzman should be transferred to a different form of detention that would allow for a bond hearing.
However, Martinotti ordered Guzman's immediate release and prohibited the government from re-arresting him under any immigration statute for 14 days. The ruling adds to mounting judicial opposition to the Biden administration's immigration detention policies and could signal broader challenges to mandatory detention practices for individuals who have established lives in the United States.