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President Donald Trump speaks alongside Homeland Security Secretary Kristi Noem during a roundtable about antifa in the State Dining Room at the White House Oct. 8, 2025 (Francis Chung/POLITICO via AP Images).
A federal judge in Minnesota has mandated the release of a Venezuelan individual in a strongly worded decision that critiques the current immigration enforcement practices in Minnesota.
This judgment scrutinizes the Trump administration’s recurrent legal battles over efforts to modify the criteria used by Immigration and Customs Enforcement (ICE) in detaining certain immigrants.
The individual, granted habeas corpus relief, persuaded U.S. District Judge John R. Tunheim, appointed by Bill Clinton, that ICE was holding him “unlawfully” in a Texas detention center.
On January 14, Gabriel Alejandro Hernandez Ledezma was taken into custody following a situation in which an ICE officer shot a man in the leg at a Minneapolis duplex, as outlined in the court’s ruling.
Post-incident, Hernandez Ledezma, who had received Temporary Protected Status (TPS) in 2024, was apprehended by ICE. He was initially detained in El Paso, then moved to a facility in San Antonio, and ultimately relocated to the T. Don Hutto Detention Center in Taylor, a site known for its controversies in the Hill Country.
“Like all Venezuelans, Petitioner’s TPS status was terminated in February 2025—however, his status is ‘in limbo,’ because a case adjudicating the lawfulness of the termination of TPS for Venezuelan citizens is currently proceeding in federal court,” Tunheim explains.
In his habeas petition, Hernandez Ledezma’s attorneys said “it is currently unknown whether ICE intends to keep him at Hutto or move him to a different facility in Texas or to a different state.”
The musical chairs-like nature of the man’s confinement is a salient point in the court’s 8-page memorandum opinion and order.
But that’s because the Trump administration raised the issue – arguing the court lacked jurisdiction to even hear the case because Hernandez Ledezma was in Texas by the time his attorneys filed.
The judge sharply rejected this line of thought.
“This habeas petition arises in the context of a concerted effort by the government to arrest residents of this state and immediately transfer them to various other detention locations, for an unstated purpose and unstated duration, without notifying Petitioner’s family or counsel as to where or when they may be transferred,” the opinion reads. “Here, in the few weeks that Petitioner has been in detention, Respondents have unilaterally changed Petitioner’s location no fewer than three times. The Court concludes that in this case, the District of Minnesota—where Petitioner resides, was arrested and detained, and was his last known permanent location—is the proper forum for Petitioner to challenge his detention as unlawful.”
The court explains that this is nothing new.
“Respondents’ practice of transferring detainees to various states, without notice or apparent justification, has made it a practical impossibility to promptly file a habeas petition in the District where the individual is presently located,” the opinion continues.
Tunheim goes on like this, explaining how a series of recent court cases in Minnesota have swiftly created precedent:
“Government-controlled transfers,” like the one in this case—often “executed within hours of detention and before communication with counsel is possible”—have been a defining characteristic of Respondents’ coordinated Operation Metro Surge program in Minnesota. In some previous cases, the Court has held that even when an individual detained in Minnesota was no longer physically located here when the petition was filed, this District is still the proper venue to hear the Petition because Petitioner’s location was unknown at the time of filing.
On the merits, the court offers a terse discussion of another series of recent court cases that turn on the limits of government’s detention under the Immigration and Nationality Act (INA).
The government claims ICE has the authority to subject immigrants to mandatory detention under 8 U.S.C. §1225(b), which applies to “aliens seeking entry into the United States.”
In the other cases the court references, judges – including Tunheim – turned instead to 8 U.S.C. §1226(a), which applies to “aliens already present in the United States.”
As has become a trend, the Trump administration prefers the detention authority under §1225(b) because of its indefinite nature — and has largely eschewed arguing for detention authority under §1226(a) because immigrants are subject to parole while their cases move forward under that statute.
The courts, almost entirely, have preferred §1226(a) but have split on whether a bond hearing or immediate release is best in terms of relief.
The present opinion is a terse and microcosm-like encapsulation of the debate between the Trump administration and judges on the one hand, and among judges themselves on the other hand.
“Section 1225(b)(2) does not authorize the warrantless, noticeless arrest of an individual already present in the United States,” Tunheim says. “Petitioner’s detention is not authorized by §1225(b)(2).”
The judge then takes stock of remedies, at length:
The Court therefore turns to the proper remedy. In some previous cases involving this issue, the Court concluded that a bond hearing pursuant to §1226(a) is the appropriate remedy. However, the Court is now persuaded that where, as here, (1) Respondents erroneously assert that a detainee is being held pursuant to §1225(b)(2); and (2) Respondents have not produced a warrant, as is required to effectuate an arrest pursuant to §1226(a), the appropriate remedy is release from custody…
“The Court will grant Gabriel A.H.L.’s petition for writ of habeas corpus and will order that he be released from custody,” the opinion concludes.