Western District of New York • 6:26-cv-06294

#1

Mar 14, 2026

PETITION for Writ of Habeas Corpus ( Filing fee $ 5 receipt number ANYWDC-5751503.), filed by Vahid Vahid Ramandi. (Attachments: # 1 Civil Cover Sheet)(Graziano, Robert) (Entered: 03/14/2026)

#2

Mar 16, 2026

TEXT ORDER re: 1 Petition for Writ of Habeas Corpus. This Court has issued Decision and Orders in Quituizaca Quituisaca v. Bondi, et al., No. 25-cv-6527, 2025 WL 3264440 (W.D.N.Y Nov. 24, 2025) and Lieogo v. Freden, et al., No. 6:25-CV-06615 EAW, 2025 WL 3290694 (W.D.N.Y. Nov. 26, 2025), finding that noncitizens who are present in the United States without having been admitted or paroled are not subject to mandatory detention under 8 U.S.C. § 1225(b)(2) but instead are subject to detention under section 1226. In addition, this Court issued Decision and Orders in Ivonin v. Rhoney, et al., No. 6:25-CV-06673 EAW, 2026 WL 199283 (W.D.N.Y. Jan. 26, 2026) and Ab-Rahim v. Marich, No. 6:26-CV-06005-EAW, 2026 WL 279113, at *1 (W.D.N.Y. Feb. 3, 2026), holding that the detention of noncitizens following expiration of parole is also governed by 8 U.S.C. § 1226, and not § 1225. The Court has also concluded based on the circumstances in these cases and a balancing of the factors under Mathews v. Eldridge, 424 U.S. 319 (1976), that due process requires the burden to be on the government at the bond hearing to establish dangerousness or flight risk by clear and convincing evidence. See, e.g., Lieogo, 2025 WL 3290694, at *4-5. In deciding whether the government has met their burden of proof, the IJ must consider whether less-restrictive alternatives to detention can reasonably address the government's interest in continued detention and if the IJ finds that the government has not met this burden, then in setting any bond the IJ must consider ability to pay and alternative conditions of release. Id.Accordingly, Respondents are hereby ORDERED TO SHOW CAUSE on or before March 23, 2026, why, in light of those decisions, the petition in this case should not be granted to the extent that it seeks an order requiring that Petitioner receive a bond hearing at which the government bears the burden to demonstrate, by clear and convincing evidence, that Petitioner is a danger to the community or a flight risk and at which the immigration judge must consider non-bond alternatives to detention or, if setting a bond, Petitioner's ability to pay.In addition, the Court temporarily enjoins Respondents from transferring Petitioner outside this District pending a resolution of the petition because the Court finds that Petitioner's presence in the District is necessary to support the Court's resolution of the issues in the petition, including because it will enable Petitioner to fully participate in these proceedings and maintain adequate access to legal counsel. See 28 U.S.C. § 2243 ("Unless the application for the writ and the return present only issues of law the person to whom the writ is directed shall be required to produce at the hearing the body of the person detained. The applicant or the person detained may, under oath, deny any of the facts set forth in the return or allege any other material facts."). This temporary order extends to the transfer of Petitioner outside the country so as to maintain the status quo and solely so that the Court can make an informed decision about its authority to issue relief and whether any relief that it has the power to issue should be granted.Further, the Clerk's Office is directed to serve a copy of the petition and this Text Order electronically via a Notice of Electronic Filing to the United States Attorney's Office, Western District of New York at USANYW-Immigration-Habeas@usdoj.gov. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 03/16/2026. (JKS)Clerk to Follow up (Entered: 03/16/2026)

Mar 16, 2026

Case assigned to Hon. Elizabeth A. Wolford. Notification to Chambers of on-line civil opening. (TF)

Mar 16, 2026

Notice of Availability of Magistrate Judge: A United States Magistrate of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form (AO-85) is available for download at http://www.uscourts.gov/services-forms/forms. (TF)

Mar 16, 2026

Clerk emailed 1 Petition to USANYW-Immigration-Habeas@usdoj.gov. (TF)

#3

Mar 23, 2026

NOTICE of Appearance by Adam A. Khalil on behalf of Todd Lyons, Tammy Marich, Kristi Noem, Philip Rhoney (Khalil, Adam) (Entered: 03/23/2026)

#4

Mar 23, 2026

REPLY/RESPONSE to re 2 Text Order, filed by Todd Lyons, Tammy Marich, Kristi Noem, Philip Rhoney. (Attachments: # 1 Form I-231, Record of Deportable/Inadmissible Alien) (Khalil, Adam) (Entered: 03/23/2026)

#5

Mar 24, 2026

ORDER granting 1 petition to the extent Petitioner seeks a bond hearing. Signed by Hon. Elizabeth A. Wolford on 03/24/2026. (JKS) Clerk to Follow up (Entered: 03/24/2026)

#6

Mar 30, 2026

Letter filed by James Bausch, Todd Lyons, Kristi Noem, Philip Rhoney re bond hearing. (Khalil, Adam) (Entered: 03/30/2026)

#7

Mar 31, 2026

TEXT ORDER. On March 30, 2026, Respondents informed the Court that a bond hearing was held and bond was set. (Dkt. 6). The Court views the issues raised by the petition as now resolved and intends to direct the Clerk's Office to close the case, unless on or before April 7, 2026, either party objects. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 03/31/2026. (JKS) (Entered: 03/31/2026)

#8

Apr 08, 2026

TEXT ORDER. On March 24, 2026, the Court granted Petitioner's petition (Dkt. 1) to the extent it seeks a bond hearing (Dkt. 5). On March 30, 2026, Respondents informed the Court that a bond hearing was held and bond was set. (Dkt. 6). The Court issued a Text Order on March 31, 2026, directing the parties to inform the Court on or before April 7, 2026, if any matters in the petition remained unresolved and to date nothing has been filed. (Dkt. 7). Accordingly, the Court dismisses any remaining claims in the petition without prejudice and directs the Clerk of Court to close the case. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 4/8/2026. (JKS)Clerk to Follow up (Entered: 04/08/2026)

#9

Apr 09, 2026

JUDGMENT dismissing without prejudice any remaining claims in the petition and the case is closed. Signed by Clerk on 4/9/26. Signed by Clerk on 4/9/26. (JHF) (Entered: 04/09/2026)

#10

Jun 08, 2026

MOTION for Miscellaneous Relief by Vahid Fasih Ramandi. (JHF) (Entered: 06/09/2026)

#11

Jun 10, 2026

TEXT ORDER re 10 Motion for Miscellaneous Relief. On March 31, 2026, the Court advised the parties that it viewed the issues raised in the petition as resolved and directed the parties to file any objections to the closure of the case by April 7, 2026. (Dkt. 7). Nothing was filed by that deadline and the Clerk of Court entered judgment on April 9, 2026, without objection. (Dkt. 9).Petitioner, now proceeding pro se, submits a letter motion seeking either immediate release or a new bond hearing, arguing that the immigration judge failed to consider his ability to pay the bond amount ($85,000) and any alternatives to detention. (Dkt. 10). The Court construes this letter as a motion to enforce the Court's Order entered on March 24, 2026 (Dkt. 5), and as seeking relief from judgment pursuant to Fed. R. Civ. P. 60(b). Responses are due on or before June 24, 2026. By that date, Respondents are also directed to provide a copy of the bond hearing transcript. Replies are due on or before July 1, 2026. Upon review of the papers, the Court will determine if oral argument is necessary and, if so, will inform the parties of the date and time. Otherwise, the matter will be deemed submitted and decided on the papers. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 06/10/2026. (JKS)This was mailed to: Petitioner. (Entered: 06/10/2026)

#12

Jun 23, 2026

Letter filed by James Bausch, Todd Lyons, Kristi Noem, Philip Rhoney with copy of bond hearing transcript. (Khalil, Adam) (Entered: 06/23/2026)

#13

Jun 23, 2026

RESPONSE in Opposition re 10 MOTION for Miscellaneous Relief filed by James Bausch, Todd Lyons, Kristi Noem, Philip Rhoney. (Khalil, Adam) (Entered: 06/23/2026)

#14

Jun 23, 2026

TEXT ORDER denying 10 Motion to Enforce and Reopen Case. On June 8, 2026, Petitioner filed a motion to enforce judgment (Dkt. 10) arguing that the Immigration Judge ("IJ") failed to consider his ability to pay the bond amount and imposed a bond amount so excessive as to constructively operate as a denial of bond. In reviewing Petitioner's motion to enforce, "it is important to emphasize that the Court's task is narrow: it is to determine whether Respondent complied with the Decision and Order, not to review the hearing evidence de novo[.]" Apollinaire v. Barr, No. 19-CV-6285-FPG, 2019 WL 4023560, at *3 (W.D.N.Y. Aug. 27, 2019); see Gutierrez Cupido v. Barr, No. 19-CV-6367-FPG, 2020 WL 103477, at *3 (W.D.N.Y. Jan. 9, 2020) (same); Nguti v. Sessions, No. 16-CV-6703, 2017 WL 5891328, at *2 (W.D.N.Y. Nov. 29, 2017) ("In reviewing the government's compliance with the May 2, 2017 order, this Court is careful not to overstep its bounds and set aside an immigration judge's bond determination on discretionary or evidentiary grounds."). Upon careful review of the bond hearing transcript (Dkt. 12), along with Petitioner's papers in support of the motion (Dkt. 10) and Respondents' opposition (Dkt. 13), the Court does not find that the IJ failed to comply with its Order. Because it is not the Court's job to substitute judgment for the IJ, the motion to enforce is denied and the request to reopen the case is denied. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 06/23/2026. (MGB) (Entered: 06/23/2026)

#15

Jul 13, 2026

MOTION for Reconsideration by Vahid Fasih Ramandi.(RE) (Entered: 07/13/2026)

#16

Jul 14, 2026

TEXT ORDER re 15 Motion for Reconsideration. Responses are due on or before July 28, 2026. The Court will not hold oral argument on the motion, but will decide the motion based on the papers submitted. SO ORDERED. Signed by Hon. Elizabeth A. Wolford on 07/14/2026. (JKS)This was mailed to: Petitioner. (Entered: 07/14/2026)

#17

Jul 22, 2026

Letter filed by James Bausch, Todd Lyons, Kristi Noem, Philip Rhoney with copy of bond hearing transcript. (Khalil, Adam) (Entered: 07/22/2026)

#18

Jul 28, 2026

RESPONSE in Opposition re 15 MOTION for Reconsideration filed by James Bausch, Todd Lyons, Kristi Noem, Philip Rhoney. (Khalil, Adam) (Entered: 07/28/2026)

#19

Aug 03, 2026

MEMORANDUM in Support re 15 MOTION for Reconsideration filed by Vahid Fasih Ramandi. (JHF) (Entered: 08/03/2026)