RIVERSIDE, Calif. — U.S. District Judge Sunshine S. Sykes on Wednesday vacated the Board of Immigration Appeals’ decision endorsing the Trump administration’s no-bond policy, undercutting a key legal foundation for mandatory detention of people arrested in interior immigration raids. She said federal agencies and immigration courts continued denying bond hearings despite her earlier judgment striking down the underlying policy, prompting her to set aside the board’s precedent under the Administrative Procedure Act, Feb. 18, 2026.
The case, Lazaro Maldonado Bautista et al. v. Ernesto Santacruz Jr. et al., challenges a 2025 shift that put many noncitizens arrested during interior operations into mandatory detention based on a new reading of the Immigration and Nationality Act. The Department of Homeland Security and the Department of Justice did not immediately respond to requests for comment.
The latest order escalates a fast-moving legal fight over how far the government can go in expanding mandatory detention without bond beyond the border and beyond categories Congress clearly made ineligible for release. It also sets up a sharper clash with a recent appeals-court decision that backed the administration’s reading of immigration law in parts of the South.
What the order says about mandatory detention and bond hearings
In a 22-page order granting a motion to enforce judgment, Sykes, an appointee of former President Joe Biden, wrote that the government had “far crossed the boundaries of constitutional conduct” by continuing to treat thousands of people as subject to detention without bond hearings.
The judge’s target was a precedential Board of Immigration Appeals ruling that immigration judges nationwide had been told to follow. Sykes said the board’s decision repeated the administration’s earlier policy guidance and could not remain in place after the court declared that legal interpretation wrong.
Vacatur: The court set aside the board’s precedent that had been used to justify mandatory detention for many people arrested away from the border.
Enforcement: The order was issued to enforce a prior final judgment that found the underlying policy unlawful under federal law and the Constitution.
Notice: Sykes directed classwide notice so eligible detainees understand they can request bond hearings rather than remain detained by default.
Reuters first detailed the decision and the court’s criticism of the administration’s continued reliance on the no-bond framework in its report on the ruling.
How the Trump no-bond policy expanded mandatory detention
At the heart of the dispute is a legal label: “applicant for admission.” Under the Immigration and Nationality Act, people treated as applicants for admission are generally subject to mandatory detention while their cases proceed and are not eligible for bond hearings.
For decades, that bond-ineligible framework was most closely associated with recent arrivals and other narrow categories. The Trump administration’s 2025 policy shift applied the same concept to people already living in the United States who were arrested during interior enforcement operations, arguing they, too, could be treated as applicants for admission.
The Board of Immigration Appeals adopted that interpretation in Matter of Yajure Hurtado, a Sept. 5, 2025, decision that said immigration judges lack authority to consider bond for people “present in the United States without admission.” The effect was sweeping: when immigration judges view someone as an applicant for admission, detention without bond follows and bond hearings stop.
Sykes previously declared the administration’s interpretation unlawful in a case brought by detainees who said they were being held without bond hearings even though, under longstanding practice, they would have been eligible to ask an immigration judge for release. In February, she concluded the government’s continued reliance on the board’s precedent required additional relief.
Why Sykes said more relief was needed
One catalyst was internal guidance from the Justice Department’s immigration court system. Sykes said Chief Immigration Judge Teresa L. Riley sent nationwide direction that immigration judges were not bound by Sykes’ earlier declaratory judgment and should continue following the board’s precedent—meaning bond hearings continued to be denied for people who, under Sykes’ reading, should have had access to them.
Sykes rejected the argument that her earlier ruling was too narrow to change day-to-day detention outcomes. The court said the government could not avoid compliance by shifting from one document to another while keeping the same legal interpretation that triggered detention without bond.
The order also criticized Department of Homeland Security messaging about who was being arrested and detained. Sykes wrote that public statements portraying enforcement as limited to the “worst of the worst” obscured how the policy was being applied to people without serious criminal records.
What happens next in the mandatory detention litigation
The administration is still defending its broader reading of the detention statutes, and the legal landscape is split. A panel of the 5th U.S. Circuit Court of Appeals recently upheld the policy’s core premise in a decision involving detainees in Texas and Louisiana, a ruling covered by The Associated Press.
Sykes noted in her order that the 5th Circuit decision is not binding on her court and said the government’s noncompliance began before that ruling. The competing decisions increase the odds that higher courts will have to reconcile what “applicant for admission” means for people arrested far from the border—and when mandatory detention can be imposed without individualized review.
For now, the practical question for detainees and lawyers is how quickly immigration judges and government attorneys will apply Sykes’ vacatur, and whether the administration seeks a stay while appeals continue.
A long-running debate over mandatory detention
The dispute is the latest chapter in a yearslong argument over detention, bond and due process. During Trump’s first term, federal officials also pushed to detain more people while their immigration cases moved slowly through backlogged courts, a shift documented in a 2018 Reuters special report.
In 2022, the Supreme Court narrowed detainees’ ability to win classwide relief and rejected a statutory right to periodic bond hearings in certain prolonged-detention cases, a ruling that advocates said made challenges to broad detention policies harder to mount at scale, as described in TIME’s coverage of the decision.
Sykes’ order, by contrast, relies on administrative law tools—including vacatur of agency action—to push back against a nationwide interpretation that, in her view, wrongly converted large numbers of interior arrestees into people subject to mandatory detention.
Whether the decision becomes a lasting break in the administration’s no-bond approach may depend on what appellate courts do next. But for detainees who fit Sykes’ class definition, the ruling is designed to reopen a path out of mandatory detention: a bond hearing before an immigration judge.
