Janeth Munoz-Munoz, a 27-year-old Mexican national who has lived in the United States since November 2023, was detained on March 20, 2026, when she appeared for a routine ICE check-in at an Enforcement and Removal Operations appointment — the very compliance she was required to perform under her Notice to Appear. ICE transferred her to Grayson County Jail in the Western District of Kentucky, where she remained while her removal proceedings continued under 8 U.S.C. § 1229a.
The legal dispute turns on a July 8, 2025 DHS interim guidance titled "Interim Guidance Regarding Detention Authority for Applicants for Admission," which ICE relied on to classify Munoz-Munoz as subject to mandatory detention under Section 1225 rather than Section 1226. Under that guidance, only noncitizens who have already been admitted to the United States are eligible for release during removal proceedings; all others are treated as applicants for admission subject to mandatory detention. Munoz-Munoz's petition characterized this as a reversal of longstanding policy, and the court cited that characterization.
The court rejected that position, holding that Section 1226 — not Section 1225(b)(2) — governs Munoz-Munoz's detention. The opinion incorporates by reference the court's prior reasoning in Edahi v. Lewis, 2025 WL 3466682 (W.D. Ky. Nov. 27, 2025), and Vicen v. Lewis, 2026 WL 541171 (W.D. Ky. Feb. 26, 2026). The court noted that Munoz-Munoz's Notice to Appear did not mark her as an "arriving alien," and that her arrest warrant was an I-200 Warrant whose authority arises from Section 1226 — both facts the government did not dispute.
On due process, the court applied the three-part Mathews v. Eldridge balancing test and held that all three factors favored Munoz-Munoz. The court held her private liberty interest substantial, the risk of erroneous deprivation high given her re-detention without any individualized assessment, and the government's burden from a routine bond hearing minimal because the procedures are already in place. The government did not address the merits of her due process claim, focusing solely on the Section 1225 versus Section 1226 question.
The court ordered Munoz-Munoz's immediate release, directed the government to provide a bond hearing before a neutral immigration judge pursuant to Section 1226 and its supporting regulations, and required the government to certify compliance by filing on the docket by April 18, 2026. The court was explicit that release followed from the unlawful detention itself, not merely from the applicability of Section 1226. The government had incorporated into its response the legal arguments it filed in four pending Sixth Circuit appeals raising the same Section 1225 versus Section 1226 question — Lopez-Campos v. Raycraft, Case No. 25-1965; Alvarez v. Noem, Case No. 25-1969; Contreras-Cervantes v. Raycraft, Case No. 25-1978; and Pizarro Reyes v. Raycraft, Case No. 25-1982 — signaling that the circuit-level resolution of those appeals will likely govern the broader dispute.