Reported / Citable
Background
Yordanis Guzman-Naranjo, a noncitizen detainee held by Immigration and Customs Enforcement (ICE), filed a habeas corpus petition under 28 U.S.C. § 2241 challenging the legality of his detention. Guzman-Naranjo entered the United States without inspection in 2021. He contended that he was erroneously categorized as subject to mandatory detention under 8 U.S.C. § 1225(b) and that his continued detention without a bond hearing violated his Fifth Amendment due process rights.
The Court’s Holding
The court dismissed the petition without prejudice. Judge Andrew S. Hanen ruled that Guzman-Naranjo’s arguments regarding mandatory detention under § 1225(b) and § 1226 were foreclosed by the Fifth Circuit’s recent decision in Buenrostro-Mendez v. Bondi, 166 F.4th 494 (5th Cir. Feb. 6, 2026).
The court further held that his Fifth Amendment due process claims were precluded by controlling Supreme Court precedent. Citing Demore v. Kim, 538 U.S. 510 (2003), the court emphasized that “[d]etention during removal proceedings is a constitutionally permissible part of that process.” The court also referenced Jennings v. Rodriguez, 583 U.S. 281 (2018), which held that §§ 1225(b)(1) and 1225(b)(2) mandate detention of applicants for admission until certain proceedings conclude.
Key Takeaways
- Detention during immigration removal proceedings is constitutionally permissible under Fifth Amendment due process analysis.
- Mandatory detention statutes for certain categories of noncitizens are not facially unconstitutional under current Supreme Court precedent.
- Recent Fifth Circuit precedent in Buenrostro-Mendez forecloses challenges to mandatory detention categorizations at the pleadings stage.
Why It Matters
This decision reinforces the constitutional permissibility of mandatory detention during removal proceedings, a significant issue in immigration litigation. The court’s reliance on Buenrostro-Mendez signals that Fifth Circuit precedent from early 2026 is now controlling the outcome of habeas petitions challenging immigration detention in that circuit.
For immigration detainees and their counsel, the decision underscores that Supreme Court precedent in Demore and Jennings creates substantial barriers to challenging detention on due process grounds, and that newer circuit-level developments may foreclose arguments that were previously viable at the pleadings stage.