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

Rigoberto Santillan Quiroz v. Mullin

Tenth Circuit · No. 26-6019 · Filed Jan 28, 2026

Latest development

Tenth Circuit mandate issued after rejection of no-bond detention theory

The June 30 opinion directs the district court, after mandate issuance, to order a bond hearing or release within seven days of the district order. Docket entry 93 records the mandate on July 22. Individual compliance and later district proceedings are not established.

Status as of
July 22, 2026
Docket reviewed through
November 9, 2026

About the case

On June 30, 2026, the Tenth Circuit rejected applying section 1225(b)(2)(A) mandatory detention to Santillan Quiroz, a long-time interior arrestee who entered without inspection. It reversed the denial of habeas relief and directed the district court, once the mandate issued, to order a bond hearing or release within seven days of its order. The appellate docket records mandate issuance on July 22. That entry does not prove a hearing or release occurred.

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

Verify district implementation separately; mandate issuance does not prove a bond hearing or release.

New on the docket, not yet reviewed

Nothing new since the last review.

Reviewed events

  1. Tenth Circuit issued mandate in mandatory-detention appeal

    Rigoberto Santillan Quiroz v. Mullin · 10th Cir. · Source

  2. Tenth Circuit rejected no-bond mandatory detention for long-time interior arrestees

    Rigoberto Santillan Quiroz v. Mullin · 10th Cir. · Source

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