Eduar I. Sanchez Nino, a Venezuelan citizen detained at the North Lake Processing Center in Baldwin, Michigan, challenged his detention under immigration law. Sanchez Nino entered the U.S. without inspection in September 2021 but was paroled into the country for one year. He was arrested again in December 2025 during a traffic stop and charged with inadmissibility for being present without admission and lacking proper documentation.
Judge Jonker concluded that Sanchez Nino should be detained under section 1226(a) of the Immigration and Nationality Act, which allows for discretionary detention, rather than the mandatory detention provisions of section 1225(b)(2). "The Court concludes that § 1226(a), not § 1225(b)(2)(A), governs noncitizens, such as Petitioner, who have resided in the United States and were already within the United States when apprehended," Jonker wrote, citing his analysis in several similar recent cases.
The government argued that Sanchez Nino had not exhausted his administrative remedies and should pursue a bond hearing through normal immigration channels. However, Jonker declined to enforce the exhaustion doctrine and found that the current detention under mandatory detention framework violated the petitioner's Fifth Amendment due process rights. The judge referenced his constitutional analysis from four similar cases decided in December 2025.
The ruling requires ICE to provide Sanchez Nino with a bond hearing under the discretionary detention statute within five business days or release him immediately. The government must file a status report within six business days certifying compliance and detailing whether bond was granted or denied. The case reflects a broader challenge to ICE detention practices for individuals who were already residing in the U.S. when re-apprehended.