W.D. Tenn. Grants Immediate Release to Long-Term Resident, Rejecting Mandatory Detention Framework

The order, issued April 17 by Chief Judge Sheryl H. Lipman, rejects the government’s argument that Ruiz Linares qualifies as an “applicant for admission” subject to mandatory detention without bond under 8 U.S.C. § 1225(b)(2)(A).

Ruiz Linares, a citizen of Colombia, entered the United States in February 2022 at age sixteen. She has lived in Memphis, Tennessee, for more than three years, working, maintaining a driver’s license, and attending church. She has no criminal history.

Immigration authorities arrested Ruiz Linares on February 10, 2026. She was detained at the West Tennessee Detention Facility in Mason, Tennessee, without a bond hearing.

The government relied on July 2025 guidance from ICE and the Department of Justice that reclassified undocumented immigrants who have lived in the U.S. for years as “applicants for admission.” This interpretation, later adopted by the Board of Immigration Appeals in Yajure Hurtado, mandates detention without bond for this group under § 1225.

Ruiz Linares filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241, challenging her detention as illegal and a violation of her constitutional rights.

Judge Lipman held that the plain language of § 1225 applies to “arriving aliens” at the border, not to individuals arrested far from the border after years of continuous presence. Applying § 1225 to Ruiz Linares would render the criminal-history exceptions in § 1226(c) superfluous.

The court further found that Congress’s recent passage of the Laken Riley Act, which added exceptions to § 1226(c), confirms that § 1226(a) remains the governing statute for discretionary detention of long-term residents.

Because § 1226(a) applies, Ruiz Linares is entitled to a bond hearing. The court held that detaining her without one violated her due process rights under the Fifth Amendment.

The order enjoins the government from pursuing Ruiz Linares’s detention under § 1225(b)(2)(A) and orders her immediate release. The government must file a status report certifying compliance by April 22, 2026.