Renzo David Canizalez Polanco, a Venezuelan national who entered the U.S. at a Texas port of entry in June 2023, was arrested by ICE agents in January 2026 while driving his daughter to school. Polanco had previously been granted Temporary Protected Status from October 2024 to April 2025 and had filed an asylum application in December 2024. He was initially paroled into the U.S. until June 2025 after being charged with inadmissibility for lacking proper immigration documents.

Judge Jarbou found that Polanco's removal order became administratively final on February 23, 2026, when his appeal period expired after the Board of Immigration Appeals rejected his appeal for insufficient filing fees. "During the removal period, the Attorney General shall detain the alien," Jarbou wrote, citing federal immigration law. The judge noted that Polanco paid $1,010 for his BIA appeal but the required fee was $1,030, leading to the rejection of his appeal.

The Detroit Immigration Court had initially dismissed removal proceedings against Polanco in June 2024, but ICE issued a new Notice to Appear in January 2026 with the same inadmissibility charges. An immigration judge ordered Polanco's removal to Venezuela on January 23, 2026, finding he had not submitted an application for relief from removal. Polanco was transferred from Michigan detention facilities to Texas and then Arizona during the proceedings.

The dismissal without prejudice leaves open the possibility for Polanco to refile his petition if circumstances change. Judge Jarbou rejected Polanco's argument that his detention violated federal law protecting TPS holders, noting that the Supreme Court allowed the termination of Venezuelan TPS to take effect pending ongoing litigation. The 90-day removal period that began February 23 has not yet expired, making Polanco's continued detention lawful under federal immigration statutes.