Guzmarina Sugey Castellano-Manzano, a Venezuelan national, was paroled into the United States in June 2023 at the Paso Del Norte port of entry in El Paso, Texas, after being issued a Notice to Appear for lacking proper immigration documents. She subsequently filed an asylum application that remains pending. In February 2026, ICE agents arrested her during a traffic stop after she dropped off children at school, issuing a second Notice to Appear that initially stated she had not been admitted or paroled, though this was later corrected to acknowledge her previous parole.
Judge Jonker found that ICE failed to follow proper procedures for terminating parole under federal regulations, which require written notice and an individualized determination that humanitarian reasons or public benefit no longer warrant the person's presence in the United States. "There is no indication in the record before the Court that any such case-by-case determination regarding the revocation of Petitioner's parole was made," Jonker wrote. The judge noted that "just as a grant of parole requires an individualized review, revocation of parole requires a case-by-case assessment to comply with the statute."
The case follows a string of similar rulings by Jonker in recent months involving ICE detainees who were paroled into the United States but later arrested without proper termination of their parole status. The government had argued that Castellano-Manzano should be denied habeas relief because she hadn't exhausted administrative remedies, but the judge declined to enforce the exhaustion doctrine.
The ruling orders ICE to release Castellano-Manzano subject to the conditions of her original parole and enjoins officials from re-detaining her absent a material change in circumstances or satisfaction of due process requirements. The decision adds to a growing body of district court precedent nationwide finding that the government must follow individualized procedures before terminating humanitarian parole grants.