Milianyony Salazar as Next Friend of Jesus Gabriel Castillo v. Kevin Raycraft et al.

District Court, W.D. Michigan·Decided June 12, 2026·No. 1:26-cv-01576·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ______

MILIANYONY SALAZAR AS NEXT FRIEND OF JESUS GABRIEL CASTILLO, Case No. 1:26-cv-1576

Petitioner, Hon. Hala Y. Jarbou

v.

KEVIN RAYCRAFT et al.,

Respondents. ____________________________/ OPINION Milianyony Salazar initiated this action by filing a pro se petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241 on behalf of Jesus Gabriel Castillo (Petitioner), a United States Immigration and Customs Enforcement (ICE) detainee currently detained at the North Lake Processing Center located in Baldwin, Lake County, Michigan. (Pet., ECF No. 1.) For the following reasons, the Court will grant Petitioner’s petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2241. Discussion I. Procedural History In Petitioner’s § 2241 petition, Petitioner challenges the lawfulness of his current detention and asks the Court to, inter alia, assume jurisdiction over this matter and issue a writ of habeas corpus pursuant to 28 U.S.C. § 2241 ordering Respondents to release Petitioner. (Pet., ECF No. 1, PageID.7.) In an order entered on May 14, 2026, the Court directed Respondents to show cause, within three business days, why the writ of habeas corpus and other relief requested by Petitioner should not be granted. (Order, ECF No. 4.) Respondents filed their response on May 19, 2026, (ECF No. 5), and Petitioner filed his reply on May 29, 2026, (ECF No. 7). II. Next Friend Status As a preliminary matter, the Court must determine whether Milianyony Salazar may proceed as “next friend” of Petitioner. A petition for a writ of habeas corpus must be in writing

and “signed and verified by the person for whose relief it is intended or by someone acting in his behalf,” known as a “next friend.” 28 U.S.C. § 2242; Whitmore v. Arkansas, 495 U.S. 149, 163 (1989). “A ‘next friend’ does not himself become a party to the habeas corpus action in which he participates, but simply pursues the cause on behalf of the detained person, who remains the real party in interest.” Whitmore, 495 U.S. at 163 (citations omitted). Next friend status, therefore, is an exception to 28 U.S.C. § 1654, which states: “In all courts of the United States the parties may plead and conduct their own cases personally or by counsel as, by the rules of such courts, respectively, are permitted to manage and conduct causes therein.” 28 U.S.C. § 1654. To act on a detainee’s behalf, a putative next friend must demonstrate that the detainee is unable to prosecute the case on her own behalf due to “inaccessibility, mental incompetence, or

other disability” and that the next friend is “truly dedicated to the best interests of the person on whose behalf he [or she] seeks to litigate.” Whitmore, 495 U.S. at 163–64 (citations omitted); see West v. Bell, 242 F.3d 338, 341 (6th Cir. 2001); Franklin v. Francis, 144 F.3d 429, 432 (6th Cir. 1998). The Whitmore Court noted that the next friend might demonstrate her dedication to the “best interests” of the real party in interest by showing “some significant relationship” with that party. Whitmore, 495 U.S. at 164. The putative next friend must clearly establish “the propriety of his status” in order to “justify the jurisdiction of the court.” Id. (citations omitted). Standing to proceed as next friend on behalf of a prisoner “is by no means granted automatically to whomever seeks to pursue an action on behalf of another.” Id. at 163. “[A] next-friend may not file a petition for a writ of habeas corpus on behalf of a detainee if the detainee himself could file the petition.” Wilson v. Lane, 870 F.2d 1250, 1253 (7th Cir. 1989) (citing Weber v. Garza, 570 F.2d 511, 513 (5th Cir. 1978)). The putative next friend “must clearly and specifically set forth facts sufficient to satisfy the[] Art[icle] III standing requirements” because “[a] federal court is powerless to create its own jurisdiction by embellishing otherwise

deficient allegations of standing.” Whitmore, 495 U.S. at 155–56 (citation omitted). Most significantly, “when the application for habeas corpus filed by a would be ‘next friend’ does not set forth an adequate reason or explanation of the necessity for resort to the ‘next friend’ device, the court is without jurisdiction to consider the petition.” Weber, 570 F.2d at 514; see Whitmore, 495 U.S. at 163. In this action, reviewing the pleadings and attached documents, the Court concludes that Milianyony Salazar, Petitioner’s spouse, has satisfied the foregoing requirements. Accordingly, the Court will permit Milianyony Salazar to proceed as next friend to Petitioner. III. Factual Background Petitioner is a native and citizen of Venezuela. (Notice to Appear (NTA), ECF No. 1-1,

PageID.12.) On November 25, 2024, Petitioner applied for admission into the United States at the Calexico, California Port of Entry. (Id.) At that time, the Department of Homeland Security (DHS) issued Petitioner a Form I-862, NTA, charging him with inadmissibility pursuant to § 212(a)(7)(A)(i)(I) of the Immigration and Nationality Act (INA) for being “an immigrant who, at the time of application for admission, is not in possession of [valid immigration and travel documents].” (Id., PageID.15.) DHS then paroled Petitioner into the United States pursuant to 8 U.S.C. § 1182(d)(5) until November 24, 2026. (Form I-94, ECF No. 1-1, PageID.16 (indicating that Petitioner’s “Class of Admission” is “DT”1).) On November 17, 2025, ICE agents arrested Petitioner. (Pet., ECF No. 1, PageID.2.) On December 8, 2025, Petitioner filed his first § 2241 petition, challenging his detention without a bond hearing. Castillo Rodriguez v. Noem (Castillo Rodriguez I), No. 1:25-cv-1688

(W.D. Mich.). The Court conditionally granted Petitioner’s petition for writ of habeas corpus and ordered that Respondents provide Petitioner with a bond hearing or, in the alternative, release him. Op. & J., Castillo Rodriguez I, (W.D. Mich. Dec. 19, 2025) (ECF Nos. 6, 7). On December 30, 2025, a bond hearing was held and an immigration judge denied Petitioner’s request for bond. Bond Order, Castillo Rodriguez I, (W.D. Mich.) (ECF No. 8-1). On May 13, 2026, Petitioner filed this § 2241 petition, challenging ICE’s initial decision to detain Petitioner. (Pet., ECF No. 1, PageID.2.) On May 8, 2026, an immigration judge ordered Petitioner removed to Venezuela. (Removal Order, ECF No. 5-1, PageID.39–42.) Petitioner filed an appeal of that decision, which

remains pending. Automated Case Information, https://acis.eoir.justice.gov/en/ (“A Number,” enter 244818258, “Nationality,” enter Venezuela, select “Submit”) (last visited Jun. 12, 2026). 2

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Milianyony Salazar as Next Friend of Jesus Gabriel Castillo v. Kevin Raycraft et al., (W.D. Mich. 2026).

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