Ali C. v. Bondi
Ali C. v. Pamela Bondi, Attorney General; Kristi Noem, Secretary, U.S. Department of Homeland Security; Todd M. Lyons, Acting Director, Immigration and Customs Enforcement; Sam Olson, Field Office Director, Fort Snelling Field Office, U.S. Immigration and Customs Enforcement; and David Isais, Jail Commander, Sherburne County Jail
- Jeffrey Bryan
- 0:25-cv-04615
- U.S. District Court · District of Minnesota
- 5
In Ali C. v. Pamela Bondi et al., Judge Jeffrey M. Bryan of the U.S. District Court for the District of Minnesota granted in part an emergency motion for a temporary restraining order, prohibiting immigration authorities from transferring Ali C. out of the District of Minnesota while his challenge to his detention is pending.
Individuals in immigration detention in the District of Minnesota who are challenging the legality of their detention via habeas corpus petitions and who face potential transfer to another jurisdiction before their cases are resolved. Also relevant to immigration attorneys and advocates handling similar cases involving Special Immigrant Juvenile status holders.
What happened
In Ali C. v. Pamela Bondi et al. (File No. 25-CV-4615), Ali C. is a Somali citizen who entered the United States in August 2022, obtained Special Immigrant Juvenile status, and was granted deferred action from removal while awaiting eligibility to apply for a green card. On December 1, 2025, U.S. Immigration and Customs Enforcement (ICE) took him into custody and has held him at the Sherburne County Jail in Elk River, Minnesota. Ali C. argues his detention is unlawful and filed an emergency motion asking the court both to release him and to block the government from moving him out of Minnesota while his case proceeds.
The court applied a four-factor test for temporary restraining orders, weighing: (1) the risk of irreparable harm to Ali C.; (2) the balance of harm between the parties; (3) the likelihood that Ali C. would succeed on the legal merits; and (4) the public interest. The court found that transferring Ali C. out of the district could cause irreparable harm by cutting off his access to his attorney, potentially eliminating the court's authority over the government officials holding him, and preventing him from participating in his own case. By contrast, the court found no identifiable harm to the government from a temporary transfer ban. The court also noted that Ali C.'s arguments raise a substantial question about whether his detention is legally justified.
Judge Jeffrey M. Bryan granted the motion in part, ordering that Respondents — including the Attorney General, the Secretary of Homeland Security, acting ICE Director, and jail officials — must not remove or transfer Ali C. from the District of Minnesota. The court declined to order his release at this time. The restraining order takes effect immediately and expires in fourteen days unless Ali C. shows good cause for an extension. The court also waived the usual requirement that the party seeking such an order post a financial bond, finding no monetary risk to the government and noting the case involves important public interests.
The detailed version
Case: Ali C. v. Pamela Bondi, Attorney General; Kristi Noem, Secretary, U.S. Department of Homeland Security; Todd M. Lyons, Acting Director, Immigration and Customs Enforcement; Sam Olson, Field Office Director, Fort Snelling Field Office, U.S. Immigration and Customs Enforcement; and David Isais, Jail Commander, Sherburne County Jail. File No. 25-CV-4615 (JMB/LIB). U.S. District Court, District of Minnesota. Judge Jeffrey M. Bryan. Order issued December 16, 2025.
Background
Ali C. is a citizen and national of Somalia who entered the United States in August 2022. He obtained Special Immigrant Juvenile (SIJ) classification — a form of immigration protection for certain young people who have been abused, neglected, or abandoned — and was granted deferred action from removal by the Department of Homeland Security (DHS), meaning DHS had agreed not to deport him for a period of time. He was awaiting eligibility to file an application for lawful permanent residence (a green card). On December 1, 2025, respondents took Ali C. into custody, and he has since been detained at the Sherburne County Jail in Elk River, Minnesota. ICE is detaining him under mandatory detention provisions of 8 U.S.C. § 1225(b)(2), which governs detention of certain individuals seeking admission to the United States. Ali C. contends this detention is unlawful.
Motion
On December 16, 2025, Ali C. filed an emergency motion for a temporary restraining order (TRO) — a short-term court order designed to preserve the status quo pending further proceedings — seeking two forms of relief: (1) an order requiring his release from custody, and (2) an order preventing respondents from transferring him out of the District of Minnesota while his underlying petition for a writ of habeas corpus (a legal challenge to the lawfulness of his detention) is pending.
Legal Standard
The court applied the four-factor Dataphase test used in the Eighth Circuit Court of Appeals for evaluating TRO and preliminary injunction motions: (1) the threat of irreparable harm to the movant; (2) the balance of harms between the parties; (3) the probability of success on the merits; and (4) the public interest. No single factor is determinative; courts weigh all circumstances flexibly. The central question is whether preserving the status quo is required by justice pending a merits determination. The moving party bears the burden of establishing these factors.
Analysis
- Irreparable harm: The court found that transferring Ali C. out of the district would cause concrete and imminent harms that could not be remedied after the fact: he could lose access to his retained attorney, the court could lose jurisdiction over the custodial respondents (because habeas jurisdiction typically requires the petitioner to be within the court's geographic reach), and Ali C. could lose his ability to participate in the litigation. The court cited Escalante v. Bondi, No. 25-CV-3051 (D. Minn. 2025), for the proposition that loss of access to retained counsel is plainly harmful to a litigant. - Balance of harms: The court found no indication that respondents would suffer any harm from a temporary prohibition on transferring Ali C. out of the district. It cited Nebraska v. Biden, 52 F.4th 1044 (8th Cir. 2022), for the principle that equities strongly favor an injunction when challenged government action would have irreversible impact but the injunction imposes no present harm on the opposing party. - Probability of success on the merits: The court found that Ali C.'s arguments raise a 'substantial question' about the legality of his detention, which was sufficient to weigh in his favor given how strongly the other factors favored him. - Public interest: The court found that preserving Ali C.'s access to judicial review and preventing potentially unlawful detention are compelling matters of public importance.
Ruling
The court granted the TRO in part. It ordered that respondents — and any other person or agency acting on their behalf — must not remove, transfer, or otherwise facilitate the removal of Ali C. from the District of Minnesota. The court denied the request for immediate release at this time. The order is effective immediately and expires fourteen days from entry (i.e., December 30, 2025) unless Ali C. shows good cause for an extension, in which case the court stated it would set a briefing schedule by separate order.
Bond Waiver
Under Federal Rule of Civil Procedure 65(c), a party obtaining a TRO is normally required to post a security bond to cover potential damages to the restrained party if the order turns out to have been wrongly granted. The court waived this requirement, finding that: (1) the TRO seeks to prevent constitutional deprivations; (2) respondents face no identifiable risk of monetary loss; and (3) the matter is closely associated with important public interests. The court cited Richland/Wilkin Joint Powers Authority v. U.S. Army Corps of Engineers, 826 F.3d 1030 (8th Cir. 2016).
Counsel
Ali C. is represented by Mail Neng Moua of Mai N. Moua Law Office, Minneapolis, MN. Respondents are represented by Ana H. Voss and Justin Merak Page of the United States Attorney's Office, Minneapolis, MN.
Reviewer note from the AI+
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