Joaquin Campos Sotelo, a Mexican national who entered the U.S. at Brownsville, Texas in July 2023, was paroled into the country for two years and applied for asylum. ICE arrested him during a traffic stop in Macomb, Michigan in February 2026 and has held him at the Calhoun County Correctional Facility in Battle Creek under mandatory detention provisions.

Judge Maloney determined that Section 1226(a) of the Immigration and Nationality Act, not the mandatory detention provision in Section 1225(b)(2)(A), governs Campos Sotelo's case because he 'resided in the United States and was already within the United States when apprehended.' The judge also found his detention under the mandatory framework 'violates Petitioner's Fifth Amendment due process rights,' citing his analysis in four similar recent cases from his court.

The government argued that Campos Sotelo should exhaust administrative remedies by pursuing a bond hearing through immigration courts first, but Maloney declined to enforce the exhaustion doctrine. The judge dismissed the Department of Homeland Security and Attorney General as respondents but retained the ICE Detroit Field Office Director and DHS Secretary to ensure his orders would be binding if Campos Sotelo is transferred.

The ruling continues a pattern of Western District of Michigan judges granting similar habeas petitions for ICE detainees, with Maloney referencing his recent decisions in at least four comparable cases from December 2025. The government must file a status report within six business days certifying compliance and detailing whether bond was granted or denied and under what conditions.