Filed Date: Jan. 12, 2026
Case Ongoing
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This is a habeas corpus case, filed by a Liberian citizen living in Minnesota who was forcibly removed from his home and detained by Immigration and Customs Enforcement (ICE) agents who entered his home without consent or a judge-issued warrant.
On June 23, 2009, an immigration judge ordered a Liberia citizen residing in Minnesota to be removed from the United States. In July, 2021, the individual was placed on an Order of Supervision which stated that the individual had not been deported or removed during the period prescribed by law, and imposed certain conditions, including enrollment in an ankle-monitoring program. Over the past four years, the individual had consistently complied with all orders of supervision, and has appeared for required check-ins with ICE. The individual has no criminal record. On January 11, 2026, ICE agents forcibly entered the individual’s home without consent or a judge-signed warrant, removed and detained him. After his detention, he did not receive a notice of custody determination or a written decision explaining circumstances that allegedly justified his detention.
On January 12, 2026, the individual filed this Petition for Writ of Habeas Corpus, and subsequently filed an Amended petition, asserting that his re-detention is unlawful because ICE failed to comply with 8 C.F.R. § 241.13, which governed his release on supervision, and that his arrest without a judicial warrant violated the Fourth Amendment. The petition further asserted that his detention was unconstitutional as a racially motivated enforcement action. The individual sought immediate release on his original conditions of release and declaratory and injunctive relief. This case was assigned to Judge Jeffrey M. Bryan in the U.S. District Court for the District of Minnesota.
On January 15, 2026, the Court granted the habeas petition in part and denied it in part. Because the government failed to file a response to the petition by January 15, 2026, as ordered by the Court, the Court treated the petition as unopposed. The Court found that ICE violated C.F.R. § 241.13 by re-detaining the petitioner without providing notice explaining the revocation of his release and demonstrating changed circumstances which would have warranted detention, and by failing to provide the petitioner a prompt, informal interview following his return to custody. The Court additionally found that the petitioner’s detention violated the Fourth Amendment because ICE agents failed to secure a warrant or consent before entering the petitioner’s home.
The Court ordered DHS to release the petitioner from custody immediately, subject to his pre-existing supervision conditions, and ordered DHS to file a status report confirming the petitioner’s release by January 16, 2026. The Court denied the other forms of relief the petitioner sought.
On January 17, 2026, the Court issued an amended judgment, which additionally prohibited ICE or DHS from arresting or re-detaining the petitioner related to any immigration proceedings without first complying with all regulations that apply to a decision to revoke orders of supervision.
This case is ongoing.
Summary Authors
Sofia Yoder (1/31/2026)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72130038/parties/gibson-v-bondi/
Brown, Trevor (Minnesota)
Prokosch, Marc (Minnesota)
Rodriguez, Juventino Meza. (Minnesota)
Voss, Ana H (Minnesota)
See docket on RECAP: https://www.courtlistener.com/docket/72130038/gibson-v-bondi/
Last updated Jan. 31, 2026, 2:13 p.m.
State / Territory:
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Operation Metro Surge
Key Dates
Filing Date: Jan. 12, 2026
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Petitioner is a Liberian citizen living in Minnesota
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Kristi Noem (Washington DC, - United States (national) -), Federal
Pamela Bondi (Washington DC, - United States (national) -), Federal
Todd Lyons (Washington DC, - United States (national) -), Federal
Marcos Charles (Washington DC, - United States (national) -), Federal
Defendant Type(s):
Case Details
Causes of Action:
Habeas Corpus, 28 U.S.C. §§ 2241-2253; 2254; 2255
Constitutional Clause(s):
Due Process: Procedural Due Process
Other Dockets:
District of Minnesota 0:26-cv-00172
Special Case Type(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Sought:
Relief Granted:
Source of Relief:
Issues
Immigration/Border: