Maldonado Bautista v. Santacruz: A Nationwide Class Restores Bond Eligibility for EWI Detainees
- Citation
- Maldonado Bautista v. Santacruz, No. 5:25-cv-01873-SSS-BFM (C.D. Cal.) (Sykes, J.); class certification Nov. 2025; final judgment Dec. 18, 2025; enforcement order Feb. 18, 2026
- Court
- U.S. District Court for the Central District of California
- Judge
- Hon. Sunshine S. Sykes
- Statute
- 8 U.S.C. §§ 1225(b)(2), 1226(a); INA § 235(b); BIA precedent in Matter of Q. Li and Matter of Yajure Hurtado
- Holding
- Class members are detained under § 1226(a), not § 1225(b)(2), and remain eligible for IJ bond hearings notwithstanding their EWI manner of entry; nationwide class certified.
The structural conflict at the heart of the 2025 immigration habeas surge is the government’s reclassification of long-resident EWI noncitizens as “applicants for admission” subject to mandatory detention under § 1225(b)(2)(A). The reclassification was operationalized by a July 8, 2025 ICE detention directive and ratified by the Board of Immigration Appeals in Matter of Q. Li (May 2025) and Matter of Yajure Hurtado (September 2025). Its effect was to strip immigration judges of authority to consider bond for tens of thousands of detainees who had previously been routinely bonded out under § 1226(a).
The most ambitious response in the federal courts was the Maldonado Bautista class action, brought in the Central District of California by a coalition of immigrant-rights groups. Judge Sunshine Sykes’s December 18, 2025 final judgment is the first nationwide class judgment squarely rejecting the administration’s position.
The statutory question
Section 1225(b)(2)(A) requires detention of “applicants for admission” pending a § 240 removal hearing. Section 1226(a) authorizes discretionary detention — with bond eligibility — of noncitizens generally pending removal proceedings. The dispositive question is which provision governs a noncitizen who entered without inspection years or decades ago and was apprehended in the interior, not at a port of entry, not at the border, not on the heels of his crossing.
The court’s answer was unambiguous. Section 1225 governs noncitizens who present themselves — or are intercepted — at the border or in immediate proximity to it. Section 1226 governs everyone else. A noncitizen who entered without inspection, established life and family in the United States, and was years later picked up by ICE in the course of ordinary interior enforcement is detained under § 1226 and is statutorily eligible for bond. The BIA’s contrary precedents were unentitled to deference following the Supreme Court’s 2024 decision in Loper Bright.
“The Government cannot, by administrative fiat, transform a long-resident immigrant into an applicant for admission and thereby strip her of the modest procedural protections Congress provided.”
Class certification
The court certified a nationwide class consisting of all detained noncitizens who entered without inspection, were not apprehended at the border, and have been denied bond hearings under the post-July 2025 enforcement framework. The certification ruling explicitly addressed and rejected the government’s argument under Garland v. Aleman Gonzalez that 8 U.S.C. § 1252(f)(1) bars classwide injunctive relief against the Attorney General’s detention authority. The court reasoned that the relief sought — a declaration of bond eligibility, not an injunction against operation of any provision — fell outside § 1252(f)(1)’s scope.
Significance and limits
Maldonado Bautista is the structural backbone of the 2025 habeas surge. It supplied the legal architecture that some 350 individual district-court orders have followed in granting habeas relief and ordering bond hearings. The American Immigration Council reported a roughly 97 percent district-court win rate on this specific question through late 2025.
The Fifth Circuit’s February 2026 decision in Buenrostro-Mendez v. Bondi, however, sided with the government on the underlying statutory question. That ruling does not directly disturb Maldonado Bautista’s judgment, but it creates a clean circuit split, eliminates bond eligibility for class members detained in the Fifth Circuit’s geography, and significantly clouds the long-term enforceability of the nationwide judgment. The Supreme Court is widely expected to take the question up. Until it does, Maldonado Bautista remains the most consequential single-judge ruling of the entire 2025 immigration docket.
Filed under Pre-Removal Detention. Published December 18, 2025.