The decision directly challenges a July 2025 Department of Homeland Security policy that directed Immigration and Customs Enforcement to treat anyone who entered without inspection as an "applicant for admission," regardless of how long they had been present in the country. The government had relied on this interpretation to justify mandatory detention under § 1225(b)(2)(A), which generally prohibits bond hearings.
Juan Carlos Castro Sanchez, the petitioner, entered the United States without inspection at least one year ago and has lived in Pennsylvania since. On April 9, 2026, ICE detained him while he was on his way to work. He was held at the Federal Detention Center in Philadelphia under the new policy, which stripped him of the right to a bond hearing.
Castro Sanchez argued that § 1225 does not apply to him because he is not actively seeking admission. He contended that his detention is governed by INA § 1226, which allows for bond hearings for noncitizens already present in the United States. He also argued that mandatory detention without a bond hearing violates his constitutional due process rights.
Judge Mary Kay Costello agreed with the petitioner. Writing in a memorandum dated April 17, 2026, she found that the plain text of § 1225 requires an individual to be "seeking admission," a phrase that connotes ongoing, affirmative steps to enter the country, typically at a border or port of entry.
The court noted that Congress used two distinct terms in the INA: "seeking admission" and "applicant for admission." Accepting the government's position that these terms are interchangeable would render one phrase entirely meaningless, the court said.
The judge distinguished the case from recent Fifth and Eighth Circuit opinions that supported the government's interpretation. She found those opinions unpersuasive and noted that a Seventh Circuit panel had previously indicated the government was unlikely to succeed on the merits of its argument.
On the due process claim, the court applied the Mathews v. Eldridge balancing test. It weighed Castro Sanchez's strong liberty interest against the government's administrative burden. The court concluded that the risk of erroneous deprivation of liberty without a neutral decisionmaker outweighed the minimal burden of providing a bond hearing.
The court granted the petition, declaring Castro Sanchez's detention under § 1225 unlawful and ordering his immediate release. The decision declines to address his Administrative Procedure Act claim, finding relief under the INA sufficient.