Cases · No-bond detention for people who entered without inspection

Jaciel Cirrus Rojas v. Samuel Olson / Scott Smith

Seventh Circuit · No. 25-3127 · Filed Dec 9, 2025

Latest development

Seventh Circuit rejected mandatory-detention theory

As of July 30, 2026, the Seventh Circuit has reversed the denial of habeas relief and held that Cirrus Rojas is governed by section 1226(a), preserving access to bond hearings for this category of interior arrestees within the circuit.

Status as of
July 30, 2026
Docket reviewed through
July 30, 2026

About the case

Cirrus Rojas v. Olson is nationally important because it adds the Seventh Circuit to the fast-moving appellate split over the administration's effort to 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. The opinion expressly aligns the Seventh Circuit with the Second, Sixth, Ninth, Tenth, and Eleventh Circuits against the Fifth and Eighth Circuits.

Relief

Cirrus Rojas sought habeas relief requiring treatment under section 1226(a) so that the immigration judge's bond order could take effect rather than mandatory detention under section 1225(b)(2)(A).

What's next

The next major milestones are any government rehearing or Supreme Court filing and how the Supreme Court handles the widening mandatory-detention circuit split.

New on the docket, not yet reviewed

Nothing new since the last review.

Reviewed events

  1. Seventh Circuit rejected no-bond mandatory detention for long-time interior arrestees

    Jaciel Cirrus Rojas v. Samuel Olson / Scott Smith · 7th Cir. · Source

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