Reyes Campos — denied habeas relief from mandatory immigration detention

Unreported / Non-Citable

Background

Kevin Alexander Reyes Campos, a citizen of El Salvador, filed a habeas petition under 28 U.S.C. § 2241 seeking release from immigration custody while his removal proceedings remained pending. He had no final removal order and was scheduled for an immigration-court master hearing on October 28, 2026.

The district court recognized that it had jurisdiction over a § 2241 challenge to pre-removal-order immigration detention. Reyes Campos contended that his custody was unlawful because he had not received a bond hearing and because mandatory detention violated due process.

The Court’s Holding

The court denied the habeas petition. It held that the Fifth Circuit’s decision in Buenrostro-Mendez v. Bondi foreclosed the argument that Reyes Campos was entitled to a bond hearing under 8 U.S.C. § 1226(a). Because he had not shown that he was “clearly and beyond a doubt entitled to be admitted,” he was subject to mandatory detention under 8 U.S.C. § 1225(b)(2)(A) during his removal proceedings.

The court also held that the Fifth Circuit’s en banc decision in Sosnava Rodriguez v. Vergara foreclosed Reyes Campos’s due-process challenge to mandatory detention under § 1225(b)(2)(A). It denied all pending motions as moot and directed the clerk to close the case.

Key Takeaways

• A noncitizen in pending removal proceedings who cannot show a clear entitlement to admission may be detained under 8 U.S.C. § 1225(b)(2)(A).
• Binding Fifth Circuit precedent foreclosed Reyes Campos’s claim to a bond hearing under 8 U.S.C. § 1226(a).
• The Fifth Circuit’s en banc precedent also foreclosed his due-process challenge to mandatory detention under § 1225(b)(2)(A).

Why It Matters

The decision applies recent Fifth Circuit precedent to reject both statutory and constitutional challenges to mandatory immigration detention while removal proceedings are pending. For similarly situated detainees in Texas, Louisiana, and Mississippi, the cited appellate rulings substantially limit habeas claims seeking bond hearings or release on those grounds.