Maldonado Bautista v. DHS is a federal class action in which a California district court ruled in December 2025 that immigrants who entered the United States without inspection cannot be held in mandatory detention and are entitled to bond hearings before an immigration judge. The Ninth Circuit has since stayed the nationwide reach of that ruling, so its protections currently apply only inside the Central District of California while the appeal proceeds and a broader circuit split moves toward the Supreme Court.
The Policy the Lawsuit Challenged
The case grew out of a July 8, 2025, ICE memorandum titled “Interim Guidance Regarding Detention Authority for Applicants for Admission.” The memo reclassified noncitizens who had entered the country without going through a port of entry as “applicants for admission” under INA § 235(b), a provision historically applied to people arriving at the border. The consequence for people already living in the country was that they were placed in mandatory detention under § 1225(b) with no chance to argue before an immigration judge that they were not a flight risk or a danger, rather than being eligible for individualized bond hearings under INA § 236(a).
On September 5, 2025, the Board of Immigration Appeals formalized that approach in a precedential decision, Matter of Yajure Hurtado, telling immigration judges nationwide they lacked authority to grant bond to anyone who had entered without inspection. The policy swept in long-term residents, including people with decades in the country, U.S. citizen family members, steady employment, and no criminal record.
The Named Plaintiffs and the Complaint
Four people detained at the Adelanto ICE Processing Center after enforcement actions in the Los Angeles area brought the case. Lead plaintiff Lazaro Maldonado Bautista had lived in Los Angeles for about four years and worked as a warehouse packer. Co-plaintiff Ana Franco Galdamez had lived in the United States for more than twenty years, was a single mother of two U.S. citizen children, and had recently finished breast cancer treatment. Ananias Pascual had also been in the country for more than two decades, had four U.S. citizen children, and had worked for the same employer since 2016. Luiz Alberto De Aquino De Aquino had been in the U.S. since 2022 and had been with his spouse for seventeen years. None had criminal records. Each was arrested in June 2025 and denied bond after an immigration judge determined mandatory detention applied.
The plaintiffs first filed a habeas petition, then amended on July 28, 2025, to add a class action complaint against DHS, ICE, and the Executive Office for Immigration Review. The case, captioned Maldonado Bautista v. Santacruz (No. 5:25-cv-01873), went to Judge Sunshine Suzanne Sykes in the U.S. District Court for the Central District of California.
The District Court Ruling
On November 20, 2025, Judge Sykes granted partial summary judgment, holding that the plaintiffs were detained under § 1226(a) and were entitled to bond hearings. Five days later she certified a nationwide “Bond Eligible Class,” defined as all noncitizens in the United States without lawful status who entered without inspection, were not apprehended upon arrival, and were not subject to other mandatory detention provisions.
Final judgment came on December 18, 2025. Judge Sykes declared the DHS policy unlawful under the Administrative Procedure Act, finding that it “broke away from the statutory framework, implementing regulations, and three decades of understanding and practice.” She wrote that it was “not the executive department’s province and duty to say what the law is.” Class members were entitled to consideration for release on bond by ICE, and to a custody hearing before an immigration judge if not released.
The Government’s Response and the February Enforcement Order
On January 13, 2026, Chief Immigration Judge Teresa L. Riley issued nationwide guidance instructing immigration judges that the Maldonado Bautista decision “is not a nationwide injunction” and directing them to continue treating Matter of Yajure Hurtado as binding. Immigration lawyers called the directive open defiance of a federal court order. Responses in the immigration courts were uneven. One New York judge granted bond hearings and then reversed course after the Riley directive; another said she was “bound” by the federal court order and kept holding hearings.
The plaintiffs moved to enforce the judgment. On February 18, 2026, Judge Sykes issued a 22-page order finding the government in noncompliance and formally vacating Matter of Yajure Hurtado under the APA. The order also required written notice to detained class members in English and Spanish, notices posted in detention facilities and on the ICE Online Detainee Locator System, weekly and biweekly reporting on detained class members, and attorney phone access within one hour of notice. Sykes described what she called “unlawful, wanton acts” and characterized the government’s position that her earlier order was not binding as “shameless.”
Between December 19, 2025, and January 30, 2026, more than 551 habeas petitions were filed in the Central District of California alone, with over 400 additional petitions granted nationwide on behalf of class members seeking bond hearings.
Where the Ruling Applies Today
The government appealed to the Ninth Circuit (Case Nos. 25-7958 and 26-1044, consolidated). An administrative stay issued on March 6, 2026, and after oral argument on March 30, the court granted a broader stay pending appeal on March 31.
The stay reaches two pieces of the district court’s work: the nationwide scope of the class certification and final judgment, and the vacatur of Yajure Hurtado. The panel found the government was likely to succeed in arguing that the district court exceeded its jurisdiction by certifying a nationwide class, reasoning that challenges to mandatory detention are habeas claims that must be brought in the district of confinement, citing the Supreme Court’s decision in Trump v. J.G.G. It also concluded the district court likely lacked authority to vacate the BIA decision because that case was already on appeal when the vacatur was entered.
So the practical picture right now: the December 2025 judgment applies only to people detained within the Central District of California. Elsewhere, its protections are suspended. Briefing has been paused pending the Ninth Circuit’s ruling in a related case, Rodriguez Vazquez v. Bostock (No. 25-6842), which presents the same statutory question.
The Circuit Split Behind the Case
The core question, whether INA § 1225(b)(2)(A) reaches long-term residents who entered without inspection and were later arrested in the interior, or whether § 1226(a) governs and bond is available, has divided the federal appellate courts.
Two circuits have sided with the government. In Buenrostro-Mendez v. Bondi (February 6, 2026), the Fifth Circuit ruled that “applicant for admission” and “seeking admission” are used interchangeably in the statute and that past executive practice cannot override the “plain text,” meaning immigration judges in Texas, Louisiana, and Mississippi may continue denying bond. In Avila v. Bondi (March 25, 2026), a 2-1 Eighth Circuit panel reached a similar result, holding that someone who has applied for admission remains “seeking” it until the application is resolved. Judge Ralph Erickson dissented, arguing the reading broke with 29 years of precedent and would render the Laken Riley Act superfluous.
Three circuits have rejected the government’s position. The Second Circuit, in Cunha v. Freden (April 28, 2026), distinguished the statutory fiction of being an “applicant for admission” from the active conduct of “seeking admission,” holding that long-term interior residents are entitled to bond hearings under § 1226(a) and flagging “grave constitutional concerns” about categorical detention without bond. The Eleventh Circuit, in Hernandez Alvarez v. Warden (May 6, 2026), similarly held that § 1225(b)(2)(A) requires both status as an applicant and active pursuit of entry, and that people arrested during traffic stops in the interior do not meet the second condition. On May 11, 2026, the Sixth Circuit held that mandatory detention of people already residing in the country violates the constitutional right to due process. A Seventh Circuit panel deadlocked on the question on May 5, 2026.
No certiorari petition had been filed as of mid-2026, but one is widely anticipated. A Congressional Research Service report described the split as deepening.
Who the Case Affects
Inside the Central District of California, detained noncitizens who entered without inspection, were not apprehended on arrival, and are not otherwise subject to mandatory detention may still request bond hearings under the surviving district court order. Outside that district, whether bond is available depends on the circuit: the Second, Sixth, and Eleventh Circuits have ruled bond hearings are required; the Fifth and Eighth have ruled they are not; and immigration judges elsewhere continue to give mixed responses. If you or a family member is in immigration detention on this basis, the location of confinement will drive what relief is currently available, and counsel familiar with the governing circuit’s law is the practical starting point.