(HC) Castillo Sanchez v. Warden of the Central Valley Annex Detention Facility et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
Jose Leonardo Castillo Sanchez
(A-Number: A-220-482-633),
Petitioner,
v.
Warden of the Central Valley Annex
Detention Facility, et al.,
Respondents.
No. 1:26-cv-05629-KES-EPG (HC)
ORDER GRANTING PETITION FOR WRIT
OF HABEAS CORPUS
Doc. 1
Petitioner Jose Leonardo Castillo Sanchez is an immigration detainee proceeding pro se
with a petition for writ of habeas corpus and motion for temporary restraining order. Docs. 1, 10.
The Court has previously addressed the legal issues raised by the petition—that, when a
noncitizen has previously been released pursuant to 8 U.S.C. § 1226(a) and is subsequently re-
detained pending removal proceedings, the Due Process Clause requires a bond hearing where the
government bears the burden of proving that the noncitizen is a flight risk or danger to the
community by clear and convincing evidence. See, e.g., Luis Alberto R.C. v. Murray, 817 F.
Supp. 3d 917 (E.D. Cal. 2025); Elmer Joel M. C. v. Wofford, No. 1:25-CV-01622-KES-CDB
Case 1:26-cv-05629-KES-EPG Document 20 Filed 10/15/26 Page 1 of 3

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(HC), 2025 WL 3501200 (E.D. Cal. Dec. 6, 2025); W.V.S.M. v. Wofford, No. 1:25-CV-01489-
KES-HBK (HC), 2025 WL 3236521 (E.D. Cal. Nov. 19, 2025); Bilal A. v. Wofford, No. 1:25-
CV-01715-KES-HBK (HC), 2025 WL 3648366 (E.D. Cal. Dec. 16, 2025); Marina V.N. v.
Robbins, No. 1:25-CV-01845-KES-SKO (HC), 2025 WL 3701960 (E.D. Cal. Dec. 21, 2025).
The Court ordered respondents to show cause as to whether there are any factual or legal issues in
this case that distinguish it from the Court’s prior orders and that would justify denying the
petition. Doc. 12.
Respondents now “concede the statutory language of the now pending misdemeanor
offense does not satisfy the requirements of 8 U.S.C. § 1226(c)(1)(E).” Doc. 19 at 1.
Respondents acknowledge that petitioner is subject to a bond hearing under 8 U.S.C. § 1226(a).
Id. Respondents argue that petitioner should be required to exhaust his administrative remedies,
but that argument is unpersuasive given respondents’ prior position that petitioner was not
eligible for a bond hearing because he was subject to mandatory detention under 8 U.S.C.
§ 1226(c). See Doc. 15. As addressed in the above-cited cases, where the government has
previously determined that a noncitizen should be released as he did not pose a flight risk or
danger, the government must bear the burden of establishing that changed circumstances warrant
his present detention.
Accordingly, the petition for writ of habeas corpus is GRANTED. Respondents are
ORDERED to provide petitioner Jose Leonardo Castillo Sanchez (A-Number: A-220-482-633)
with a bond hearing before a neutral decisionmaker within fourteen (14) days of the date of this
Order. Respondents shall immediately provide petitioner with a copy of this Order and shall
provide him with 72 hours’ notice before the bond hearing in a language that he can
understand. At that bond hearing, it is respondents’ burden to demonstrate that petitioner is a
flight risk or danger to the community by clear and convincing evidence. Petitioner may be
represented by an attorney at this hearing, and respondents may extend the deadline at petitioner’s
request so that he can obtain an attorney. If petitioner obtains an attorney, his attorney shall also
be given 72 hours’ written notice before the bond hearing. The neutral decisionmaker must
consider petitioner’s financial circumstances in setting the amount of bond and alternative
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conditions of release in lieu of detention without bond. If respondents do not provide petitioner
with a bond hearing within fourteen (14) days, then respondents must release him.
The Clerk of Court is directed to close this case and enter judgment for petitioner. The
Clerk is directed to serve Central Valley Annex with a copy of this Order.
IT IS SO ORDERED.
Dated: October 14, 2026
UNITED STATES DISTRICT JUDGE
Case 1:26-cv-05629-KES-EPG Document 20 Filed 10/15/26 Page 3 of 3