J.M.G. v. Warden, Stewart Detention Center - Immigration Habeas Corpus

Middle District of Georgia Opinions

Filed January 22nd, 2026

Detected February 26th, 2026

Summary

The U.S. District Court for the Middle District of Georgia granted a petitioner's habeas corpus relief, ordering the Warden of Stewart Detention Center to provide the detainee with a bond hearing. The court found the detainee was not subject to mandatory detention under the cited statutes.

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What changed

In J.M.G. v. Warden, Stewart Detention Center, et al., Case No. 4:26-cv-63-CDL-ALS, the U.S. District Court for the Middle District of Georgia granted a petitioner's application for habeas corpus relief. The court determined that the petitioner, an immigration detainee awaiting removal proceedings, was being detained under 8 U.S.C. § 1226(a) and was therefore not subject to mandatory detention under 8 U.S.C. § 1225(b)(2). The court ordered the respondents to provide the petitioner with a bond hearing to determine eligibility for pre-removal release on bond.

This ruling has immediate implications for immigration detainees in similar situations, particularly those held at Stewart Detention Center. Regulated entities, specifically detention facility operators and immigration agencies, must comply with the court's order by conducting bond hearings for detainees found to be under § 1226(a) detention. Failure to comply could result in further legal action. The order implies a need for review of current detention practices to ensure compliance with statutory and regulatory requirements for bond hearings.

What to do next

Review detention status of individuals held under 8 U.S.C. § 1226(a)
Conduct bond hearings for eligible detainees awaiting removal proceedings
Ensure compliance with 8 C.F.R. §§ 236.1 & 1236.1.1

Source document (simplified)

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Jan. 22, 2026 Get Citation Alerts Download PDF Add Note

J.M.G. v. Warden, STEWART DETENTION CENTER, et al.

District Court, M.D. Georgia

Citations: None known
Docket Number: 4:26-cv-00063
Precedential Status: Unknown Status
Opinion
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Cited By (0)
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Trial Court Document

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF GEORGIA

COLUMBUS DIVISION

J.M.G., :

:

Petitioner, :

:

v. : Case No. 4:26-cv-63-CDL-ALS

: 28 U.S.C. § 2241 Warden, STEWART DETENTION :

CENTER, et al., :

:

Respondents. :

                     ORDER

Petitioner is a detainee at the Stewart Detention Center awaiting removal
proceedings. Petitioner seeks habeas corpus relief based on Respondents’ refusal to
provide Petitioner with a bond hearing and the opportunity for pre-removal release
while the removal proceedings are pending. Respondents contend that Petitioner’s
detention is mandatory under 8 U.S.C. § 1225 (b)(1) and/or 8 U.S.C. § 1225 (b)(2).

The Court reviewed Petitioner’s application. The Court finds that Petitioner is
currently detained under 8 U.S.C. § 1226 (a) and therefore not subject to mandatory
detention as required by 8 U.S.C. § 1225 (b)(2). See J.A.M. v. Streeval, No. 4:25-CV-342-
CDL, 2025 WL 3050094 (M.D. Ga. Nov. 1, 2025); P.R.S. v. Streeval, No. 4:25-CV-330-
CDL, 2025 WL 3269947 (M.D. Ga. Nov. 24, 2025). Accordingly, Petitioner’s application
for habeas corpus relief is granted to the extent that Respondents shall provide
Petitioner with a bond hearing to determine if the Petitioner may be released on bond
under § 1226(a)(2) and the applicable regulations. See 8 C.F.R. §§ 236.1 & 1236.1.1
IT IS SO ORDERED, this 22nd day of January, 2026.

s/Clay D. Land

CLAY D. LAND

U.S. DISTRICT COURT JUDGE

MIDDLE DISTRICT OF GEORGIA

1 The brevity of this order is appropriate given that the issue presented is exactly the same as the issue
previously decided on numerous occasions by the Court and yet Respondents insist upon denying the
relief that the Court has found is required.