Yalfrison Enrique Duran-Rodriguez v. Kristi Noem, et al.
- Proceeding
- district
- Area
- civil
- Panel
- Cathy Ann Bencivengo (author)
Analysis
The court considered a habeas corpus petition filed by an ICE detainee alleging detention without a bond hearing in violation of 8 U.S.C. § 1226(a) and the Fifth Amendment. The court ordered the respondents to provide the petitioner with an individualized bond hearing by January 5, 2026, and to report the status of that hearing by January 7, 2026.
| What the court decided | The model |
|---|---|
Order requiring Respondents to provide Petitioner an individualized bond hearing by January 5, 2026“The Court thus ORDERS Respondents to provide Petitioner an individualized bond hearing before an immigration judge pursuant to 8 U.S.C. § 1226(a) and its associated regulations by January 5, 2026.” | agree with court The order relies on the Respondents' Supplemental Brief, which acknowledges that the Petitioner is a member of a certified class in a related case (Maldonado Bautista v. Santacruz) where final judgment was entered. The Respondents explicitly acknowledge that the Petitioner is detained under 8 U.S.C. § 1226(a) and is entitled to a bond hearing. Given this stipulation by the government and the reference to a final judgment in a related class action, the court's order to provide the hearing follows logically from the record presented. |
Order requiring Respondents to update the Court on the status of the bond hearing by January 7, 2026“Respondents are further ORDERED to update this Court the status of Petitioner’s bond hearing by January 7, 2026.” | agree with court This is a procedural directive to ensure compliance with the primary order. It is a standard case management measure to allow the court to dismiss the case once compliance is confirmed. |
The order itself: sound with gaps — The order is procedurally sound as it relies on the government's own admission and a final judgment in a related class action. However, it is a very brief order that does not independently analyze the legal merits of the § 1226(a) claim or the Fifth Amendment claim, instead relying entirely on the stipulation in the Supplemental Brief. While defensible given the stipulation, it skips the independent judicial analysis typically expected in a habeas ruling.
How this analysis was made · dispute it
record incompleteOpinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 YALFRISON ENRIQUE DURAN- Case No.: 25-cv-03096-CAB-DEB RODRIGUEZ, 12 ORDER REQUIRING A BOND Petitioner, 13 HEARING v. 14 [Doc. No. 1] KRISTI NOEM, et al., 15 Respondents. 16 17 Pending before the Court is a petition for a writ of habeas corpus pursuant to 28 18 U.S.C. § 2241 filed by Yalfrison Enrique Duran-Rodriguez (“Petitioner”). [Doc. No. 1 19 (“Petition”).] Petitioner asserts he is being detained by Immigration and Customs 20 Enforcement (“ICE”) without a bond hearing in violation of 8 U.S.C. § 1226(a) and the 21 Fifth Amendment. [Id. at 7–10.] 22 On December 19, 2025, Respondents filed a Supplemental Brief stating that: 23 Petitioner appears to be a member of the Bond Eligible Class certified in 24 Maldonado Bautista v. Santacruz, No. 5:25-CV-01873-SSS-BFM, --- F. 25 Supp. 3d ---, 2025 WL 3288403 (C.D. Cal. Nov. 25, 2025). The Bautista court has entered final judgement as to the Bond Eligible Class. Bautista, 26 [Doc. No.] 94. Accordingly, Respondents acknowledge that Petitioner is 27 detained under 8 U.S.C. § 1226(a) and [is] entitled to an order from this Court directing a bond hearing be held pursuant to 8 U.S.C. § 1226(a). 28 1 [Doc. No. 10 at 2.] 2 The Court thus ORDERS Respondents to provide Petitioner an individualized bond 3 ||hearing before an immigration judge pursuant to 8 U.S.C. § 1226(a) and its associated 4 ||/regulations by January 5, 2026. Respondents are further ORDERED to update this Court 5 the status of Petitioner’s bond hearing by January 7, 2026. Once Respondents confirm 6 || Petitioner has received an individualized bond hearing, the Court will dismiss the case. 7 It is SO ORDERED. 8 9 || Dated: December 22, 2025 □ 10 Hon. Cathy Ann Bencivengo United States District Judge 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28