Cases · No-bond detention for people who entered without inspection
Rigoberto Santillan Quiroz v. Mullin
Latest development
Tenth Circuit rejected mandatory-detention theory
As of June 30, 2026, the Tenth Circuit has reversed the denial of habeas relief and instructed that Santillan Quiroz receive a bond hearing or be released within seven days.
- Status as of
- June 30, 2026
- Source
- Latest order (PDF)
- Docket reviewed through
- June 30, 2026
About the case
Rigoberto Santillan Quiroz v. Mullin is nationally important because the Tenth Circuit added another published appellate ruling to the fast-moving split over whether the administration can treat long-time interior arrestees who entered without inspection as mandatory-detention applicants for admission under INA section 1225(b)(2)(A). The panel held that section 1226(a), not section 1225(b)(2)(A), governs this category of detainees and reversed the denial of habeas relief.
Relief
The petitioner sought habeas relief requiring treatment under section 1226(a) so that an immigration judge could consider release on bond rather than mandatory detention.
What's next
The next major milestones are any rehearing or Supreme Court filing and whether the now broader Fifth-Eighth versus Second-Sixth-Tenth-Eleventh split produces Supreme Court review.
New on the docket, not yet reviewed
Nothing new since the last review.
Reviewed events
Tenth Circuit rejected no-bond mandatory detention for long-time interior arrestees
Rigoberto Santillan Quiroz v. Mullin · 10th Cir. · Source
In the news
- ACLU of Colorado case pageACLU of Colorado · May 12, 2026