Anzor Dzhumaev, a Chechen national who entered the U.S. without inspection in 2022, was initially released on recognizance after one month of detention and worked legally in the country until February 2025. Immigration officials re-detained him when he appeared for a check-in after missing one appointment, though he had reported in person three weeks later upon ICE's request. Dzhumaev has a pending asylum application filed in 2023 and no criminal record.
Judge Holcomb found that all three factors of the constitutional Mathews test favored Dzhumaev, concluding that "procedural Due Process requires a pre-deprivation hearing on the merits." The judge emphasized that "the Government's interest in detaining Dzhumaev without providing notice and hearing is minimal because the effort and cost required to provide Dzhumaev with procedural safeguards is minimal." The court also noted that Dzhumaev was denied a fair bond hearing when officials cancelled it due to lack of a translator, despite his counsel's willingness to proceed.
The Central District of California previously granted Dzhumaev's first motion for a temporary restraining order in February, directing that he receive a bond hearing by March 4, 2026. However, that hearing was cancelled when immigration court failed to provide a translator. Dzhumaev filed his renewed motion for preliminary injunction two weeks after the cancelled hearing, which the government confirmed occurred due to translator unavailability.
Judge Holcomb's order requires Dzhumaev's release under his pre-existing conditions but notes the ruling "does not provide Dzhumaev with blanket immunity from future detention," clarifying that any future enforcement actions must comply with due process requirements. The decision joins numerous similar rulings in the Central District finding due process violations in ICE detention cases, with the court referring the case to a magistrate judge for further proceedings on the merits.