Filed Date: Jan. 8, 2026
Case Ongoing
Clearinghouse coding complete
On January 8, 2026, petitioner Juan Tobay Robles filed a petition for habeas corpus in the District Court of Minnesota. The petitioner, a citizen of Ecuador, entered the United States without inspection as a minor. Immigration and Customs Enforcement (ICE) detained him on January 6, and placed him in custody. Tobay Robles' petition is one of numerous recent cases challenging the application of 8 U.S.C. § 1225(b)(2) to noncitizens who have been living in the United States unlawfully.
The Minnesota court recently held that, because such noncitizens are not “seeking admission,” that provision does not apply to them. See Santos M.C. v. Olson, 2025 WL 3281787, at *3 (D. Minn. Nov. 25, 2025). The petitioner named the following as respondents: Kristi Noem, in her official capacity as Secretary of the Department of Homeland Security; Todd Lyons, in his official capacity as Acting Director of ICE; and David Easterwood, in his official capacity as Acting Director, St. Paul Field Office, U.S. ICE.
Magistrate Judge Douglas L. Micko ordered the government to show cause why the petition should not be granted and whether this case could be distinguished from Santos M.C. v. Olson. After the government failed to respond the court granted the petition and ordered that if the government did not provide the petitioner with a bond hearing under 8 U.S.C. § 1226(a) within seven days of the date of the order, the petitioner must be immediately released from detention.
On January 23, three days after the court’s seven-day deadline, the petitioner notified the court that ICE did not provide him a bond hearing and continued to detain him. Days later, on January 26, Chief Judge Patrick J. Schiltz ordered Todd Lyons, the director Acting Director of ICE, to appear in person to show cause as to why he should not be held in contempt for violating the court's order granting the petition. Judge Schiltz wrote that,
This Court has been extremely patient with respondents, even though respondents decided to send thousands of agents to Minnesota to detain aliens without making any provision for dealing with the hundreds of habeas petitions and other lawsuits that were sure to result. Respondents have continually assured the Court that they recognize their obligation to comply with Court orders, and that they have taken steps to ensure that those orders will be honored going forward. Unfortunately, though, the violations continue. The Court’s patience is at an end.
Judge Schiltz added that the hearing would be canceled in the event that Respondents published a stipulation verifying Petitioner's release. Recognizing that this was an "extraordinary step," the court nonetheless found this measure to be justified in light of ICE's violation of court orders. 2026 WL 200329. Robles was released from custody the following week, with Respondents filing their stipulation to this effect on January 28, 2026. The hearing, scheduled for January 30, 2026, was summarily canceled.
On February 26, 2026, Judge Schiltz issued a supplemental order in response to U.S. Attorney for the District of Minnesota Daniel Rosen emailing the Judge to criticize his earlier order. Rosen alleged that Judge Shiltz's January 28 order accusing ICE of violating 96 court orders in 74 cases was "far beyond the pale of accuracy." Instead of inaccuracy, Appendix A attached to the supplemental order provided evidence that ICE in fact violated 97 orders in 66 of the cases referred to in the January 28 order. Further, Appendix B provides a list of additional times ICE violated court orders after the January 28 order - 113 violations in 77 cases. Judge Schiltz also noted that DOJ attorneys in Minnesota had been put in an impossible position by the Trump Administration's decision to flood Minneapolis/St. Paul with ICE agents without a plan for dealing with the resulting surge in court cases.
Judge Schiltz wrapped up his supplemental order by writing that "this court will continue to do whatever is required to protect the rule of law, including, if necessary, moving to the use of criminal contempt. One way or another, ICE will comply with this Court's orders."
This case has concluded.
Summary Authors
Jinan Abufarha (1/30/2026)
Ben Hefter (2/25/2026)
Nick Martire (3/14/2026)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72120823/parties/tobay-robles-v-noem/
Schiltz, Patrick Joseph (Minnesota)
Voss, Ana H (Minnesota)
Ojala-Barbour, Graham Blair (Minnesota)
See docket on RECAP: https://www.courtlistener.com/docket/72120823/tobay-robles-v-noem/
Last updated April 20, 2026, 3:16 a.m.
State / Territory:
Case Type(s):
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Key Dates
Filing Date: Jan. 8, 2026
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
The petitioner is, a citizen of Ecuador, who entered the United States without inspection as a minor.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
City
David Easterwood
Federal
Kristi Noem
Todd Lyons
Case Details
Causes of Action:
All Writs Act, 28 U.S.C. § 1651
Other Dockets:
District of Minnesota 0:26-cv-00107
Special Case Type(s):
Available Documents:
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Sought:
Relief Granted:
Source of Relief:
Issues
General/Misc.:
Case Summary of Tobay Robles v. Noem, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/47771/ (last updated 3/14/2026).