Jeimy Hernandez Gomez v. James A. Daley, et al.

CourtDistrict Court, E.D. Kentucky
DecidedJanuary 30, 2026
Docket2:25-cv-00150
StatusUnknown

This text of Jeimy Hernandez Gomez v. James A. Daley, et al. (Jeimy Hernandez Gomez v. James A. Daley, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jeimy Hernandez Gomez v. James A. Daley, et al., (E.D. Ky. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION at Covington

JEIMY HERNANDEZ GOMEZ, ) ) Petitioner, ) Civil Action No. 2:25-cv-00150-SCM ) v. ) MEMORANDUM OPINION ) AND ORDER JAMES A. DALEY, et al., ) ) Respondents. ) )

*** *** *** *** Jeimy Hernandez Gomez is a noncitizen who has been detained without bond by the Department of Homeland Security while undergoing removal proceedings. She has filed a petition for a writ of habeas corpus on the ground that it is unlawful for DHS to detain her without a bond hearing. But she is not entitled to a bond hearing. To the contrary, the applicable statutory language provides that she “shall be detained” during removal proceedings. 8 U.S.C. § 1225(b)(2)(A). Accordingly, her habeas petition is denied. I. Facts The Petitioner, Jeimy Hernandez Gomez, is a Guatemalan citizen who came to the United States in 2013. [Dkt. 1 at 1]. She entered the United States as a minor without authorization or inspection. [Id.]. On June 22, 2016, a Border Patrol Agent issued the Petitioner a Notice to Appear charging her with being an alien present in the United States without having been admitted or paroled. [Dkt. 8-1 at 2]. Then on August 3, 2016, an immigration judge ordered the Petitioner to be removed to Guatemala after she failed to appear for the immigration court hearing. [Id. at 1; Dkt. 1 at 2]. In May 2025, United States Immigration and Customs Enforcement

apprehended and detained the Petitioner pursuant to the removal order. [Dkt. 1 at 4]. An immigration judge then reopened the Petitioner’s removal proceedings but denied her request for a bond hearing based on the Board of Immigration Appeals’ ruling in Matter of Yajure Hurtado, 29 I. & N. Dec. 216 (BIA 2025), that aliens situated like the Petitioner are not entitled to bond hearings under 8 U.S.C. § 1225(b)(2). [Id.; Dkt. 15-1 at 1]. She is currently detained at the Campbell County

Detention Center in Newport, Kentucky. [Dkt. 1 at 3]. The Petitioner then filed her Petition for a Writ of Habeas Corpus on September 30, 2025. [Id. at 1]. The Respondents include James Daley as Jailer of the Campbell County Detention Center and Russell Hott as the Field Office Director for ICE’s Chicago office. [Id. at 3–4]. The Petitioner argues that her detention without bond violates her right to due process under the Fifth Amendment and the plain text of the Immigration and Nationality Act. [Id. at 13–15]. According to the

Petitioner, her detention is governed by 8 U.S.C. § 1226(a) instead of 8 U.S.C. § 1225(b)(2), meaning she is entitled to a bond hearing. [Id. at 15]. Thus, she seeks relief through a writ of habeas corpus, which “is at its core a remedy for unlawful executive detention.” Munaf v. Geren, 553 U.S. 674, 693 (2008). And she asks this Court to reject Yajure Hurtado’s interpretation of the INA, agree with the federal judges who have found that detention like hers is unlawful, and endorse her understanding of the INA. [Dkt. 9 at 1–4]. She requests an order prohibiting the Respondents from transferring her out of the Eastern District of Kentucky and a bond hearing for her removal proceedings. [Dkt. 1 at 16].

After Responses and a Reply were filed, the Petitioner filed a Motion for a Temporary Restraining Order and Preliminary Injunction, [Dkt. 15], seeking her immediate release or a bond hearing. II. Analysis This case boils down to one question: Is the Petitioner’s detention governed by 8 U.S.C. § 1225(b)(2), which would preclude her from receiving a bond hearing, or is

it governed by 8 U.S.C. § 1226(a), which would allow a bond hearing? This question has arisen in numerous cases nationwide due to the BIA’s determination in 2025 that all aliens who have not been admitted into the country must be detained without bond “unless an immigration officer determines that they are ‘clearly and beyond a doubt entitled to be admitted.’” Yajure Hurtado, 29 I. & N. Dec. at 228 (quoting 8 U.S.C. § 1225(b)(2)(A)). Following that decision, DHS began detaining aliens situated similarly to the Petitioner without bond hearings. This

signaled a shift in practice. Previously, aliens who were present in the United States without admission and who were apprehended within the United States generally were given a bond hearing pursuant to 8 U.S.C. § 1226(a). But now, during the Petitioner’s present detention, the BIA’s more recent interpretation of the INA in Yajure Hurtado has prevented her from receiving a bond hearing. As explained above, the Petitioner argues that her detention without bond is unlawful. She believes the prior agency practice reflects the correct interpretation of the INA. Pointing to Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), the

Petitioner argues that this Court should not defer to the new interpretations of the BIA and DHS. Fair enough. The Petitioner is correct that agency deference is a thing of the past. See Loper Bright, 603 U.S. at 392. But that just means the Court must exercise independent judgment in saying what the law is. See id. at 385 (quoting Marbury v. Madison, 1 Cranch 137, 177 (1803)). It does not mean that the Court is obligated to conclude that the BIA and DHS are wrong and the Petitioner is right. To

the contrary, the Petitioner is the one who is wrong. A straightforward application of the plain language of the relevant statute compels the conclusion that she must be detained during her removal proceedings. Thus, she is not entitled to a bond hearing. See Singh v. Noem, No. 2:25-cv-00157-SCM, 2026 WL 74558 (E.D. Ky. Jan. 9, 2026). A. Section 1225(b)(2) applies to the Petitioner, thereby making her subject to mandatory detention. The two statutes that potentially govern the Petitioner’s detention are 8 U.S.C. § 1225(b)(2) and 8 U.S.C. § 1226(a). In relevant part, § 1225(b)(2)(A) provides: [I]n the case of an alien who is an applicant for admission, if the examining immigration officer determines that an alien seeking admission is not clearly and beyond a doubt entitled to be admitted, the alien shall be detained for a proceeding under section 1229a of this title.

And § 1226(a), in relevant part, provides: On a warrant issued by the Attorney General, an alien may be arrested and detained pending a decision on whether the alien is to be removed from the United States. Except as provided in subsection (c) and pending such decision, the Attorney General— (1) may continue to detain the arrested alien; and (2) may release the alien on— (A) bond of at least $1,500 with security approved by, and containing conditions prescribed by, the Attorney General; or (B) conditional parole . . . . The scope of the two statutes is obviously different. Section 1226(a) potentially applies to any alien who is arrested on a warrant issued for removal proceedings. Section 1225(b)(2), however, is narrower.

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Related

Marbury v. Madison
5 U.S. 137 (Supreme Court, 1803)
Almendarez-Torres v. United States
523 U.S. 224 (Supreme Court, 1998)
Munaf v. Geren
553 U.S. 674 (Supreme Court, 2008)
Zadvydas v. Davis
533 U.S. 678 (Supreme Court, 2001)
Jennings v. Rodriguez
583 U.S. 281 (Supreme Court, 2018)
Rimini Street, Inc. v. Oracle USA, Inc.
586 U.S. 334 (Supreme Court, 2019)
Atlantic Richfield Co. v. Christian
590 U.S. 1 (Supreme Court, 2020)
Department of Homeland Security v. Thuraissigiam
591 U.S. 103 (Supreme Court, 2020)
Yajure Hurtado
29 I. & N. Dec. 216 (Board of Immigration Appeals, 2025)

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Bluebook (online)
Jeimy Hernandez Gomez v. James A. Daley, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeimy-hernandez-gomez-v-james-a-daley-et-al-kyed-2026.