Ijeoma C. v. Bondi
Ijeoma C. v. Pamela Bondi, U.S. Attorney General; Kristi Noem, Secretary, U.S. Department of Homeland Security; Todd M. Lyons, U.S. Immigration and Customs Enforcement Acting Director; Marco Charles, Enforcement and Removal Operations, Acting Executive Director; Eric Klang, Sheriff, Crow Wing County Jail
- Jeffrey Bryan
- 0:25-cv-04770
- U.S. District Court · District of Minnesota
- 6
In Ijeoma C. v. Pamela Bondi, Judge Jeffrey M. Bryan granted in part an emergency temporary restraining order (TRO), prohibiting the government from transferring a Nigerian woman out of the District of Minnesota while her court challenge to her detention and deportation remains pending, but denied her request to stop the deportation itself.
Noncitizens in immigration detention in the District of Minnesota who have pending immigration applications or habeas petitions challenging their detention or removal, particularly those subject to Final Administrative Removal Orders and detained under 8 U.S.C. § 1225(b)(2).
What happened
In Ijeoma C. v. Pamela Bondi, Ijeoma C. is a Nigerian-born noncitizen who entered the United States lawfully in 2017, was convicted of conspiracy to commit international money laundering in 2023, and cooperated with the government — cooperation that has led to death threats against her if she returns to Nigeria. She is the sole caregiver for her U.S. citizen child and has several immigration applications pending, including requests for asylum, protection from removal to Nigeria, and relief under the Violence Against Women Act. She had not yet received hearings on any of those applications when Immigration and Customs Enforcement (ICE) detained her on December 4, 2025, and the Department of Homeland Security issued a Final Administrative Removal Order on December 22, 2025. She also alleges she was denied access to her attorney during detention.
Ijeoma C. filed a petition for a court order challenging her detention and removal (a legal tool that asks a federal court to review whether the government is holding someone lawfully), and then filed an emergency TRO asking the court to block both her transfer out of the district and her deportation to Nigeria. She argued that being transferred or deported before the court could rule on her petition would cause irreparable harm — including loss of access to her lawyer, inability to participate in the litigation, and potential persecution or death in Nigeria.
Judge Jeffrey M. Bryan granted the motion in part, ordering that the government may not remove, transfer, or facilitate the removal of Ijeoma C. from the District of Minnesota while her petition is pending, and must not block her access to her attorney. The court found that the risk of irreparable harm to Ijeoma C. from a transfer — including loss of counsel and potential deportation to a country where she faces death threats — outweighed any burden on the government, which the court found would face no identifiable harm from the temporary transfer restriction. The court denied the broader request to stop her deportation entirely, and noted that courts across the country have repeatedly rejected the government's legal interpretation supporting mandatory detention of people in Ijeoma C.'s situation. The TRO expires in fourteen days unless extended, and the court indicated it expects to issue a ruling on the underlying petition within ten days of receiving the government's response, due January 5, 2026.
The detailed version
Case: Ijeoma C. v. Pamela Bondi, U.S. Attorney General, et al., File No. 25-CV-4770 (JMB/ECW), U.S. District Court for the District of Minnesota. Judge: Jeffrey M. Bryan.
BACKGROUND Petitioner Ijeoma C. is a Nigerian national who entered the United States lawfully in 2017. She is the sole caregiver for her U.S. citizen child. In April 2023, she was convicted in federal court of Conspiracy to Commit International Money Laundering. She provided substantial assistance to the government in connection with that conviction, which has exposed her to retaliation — including death threats — from individuals involved in fraud schemes should she return to Nigeria.
Ijeoma C. has multiple immigration-related applications pending: (1) a Violence Against Women Act (VAWA) petition seeking immigrant classification as an abused spouse of a U.S. citizen; (2) an asylum application; (3) an application for withholding of removal to Nigeria; and (4) a request for protection under the Convention Against Torture. None of these had been the subject of interviews or hearings at the time of the motion.
ICE took Ijeoma C. into custody on December 4,
- On December 22, 2025, the Department of Homeland Security (DHS) issued a Final Administrative Removal Order for her deportation to Nigeria, notwithstanding her pending applications. She alleges she was denied access to counsel during her detention. She filed a habeas petition — a legal challenge asking a federal court to review the lawfulness of her detention and removal proceedings — on December 23,
- The petition was assigned to Judge Bryan on December 29,
- On December 30, 2025, she filed the emergency TRO motion.
RELIEF REQUESTED The TRO motion sought two forms of relief: (1) an order prohibiting Respondents from transferring or transporting her out of the District of Minnesota; and (2) an order prohibiting her removal or deportation to Nigeria. The court granted the first and denied the second.
LEGAL STANDARD The court applied the four-factor test from Dataphase Systems, Inc. v. C L Systems, Inc., 640 F.2d 109, 114 (8th Cir. 1981), which is also the standard for preliminary injunctions: (1) threat of irreparable harm to the movant; (2) balance of harms between the parties; (3) probability of success on the merits; and (4) the public interest. No single factor is dispositive; the court flexibly weighs all circumstances. The movant bears the burden of establishing these factors.
ANALYSIS
1. Irreparable Harm: The court found that transferring Ijeoma C. out of the District would cause concrete, imminent, and unremediable harm: loss of access to retained counsel (which the court described as plainly harmful to a litigant's ability to present her case, citing Escalante v. Bondi, No. 25-CV-3051, D. Minn. 2025); potential inability to participate in the litigation; risk that her pending asylum, withholding of removal, VAWA, and Convention Against Torture applications would be rendered moot; and potential deportation to Nigeria, where she faces death threats. The court cited Fuentes v. Olson, No. 25-CV-4456 (D. Minn. 2025), for the proposition that unlawful detention is a prime example of irreparable harm.
2. Balance of Harms: The court found no indication that Respondents would suffer any harm from a temporary transfer prohibition while the petition is pending. The court cited Nebraska v. Biden, 52 F.4th 1044, 1047 (8th Cir. 2022), for the contrast between the irreversible impact on Ijeoma C. and the lack of harm to the government.
3. Likelihood of Success on the Merits: The court noted that Respondents had not yet filed a response (due January 5, 2026) and that Ijeoma C.'s petition raises issues specific to her circumstances. However, the petition also challenges her detention under 8 U.S.C. § 1225(b)(2), which applies to persons seeking admission. The court observed that courts across the country have 'overwhelmingly rejected' the government's interpretation of § 1225 as a basis for mandatory detention, citing Fuentes v. Olson (noting nearly 300 adverse rulings against the government's position). The court concluded Ijeoma C. would likely succeed on this ground and declined to analyze likelihood of success further.
4. Public Interest: The court found the public interest in ensuring due process, judicial review, and the rule of law outweighs the interest in deporting Ijeoma C. before her petition is reviewed.
ORDER The court granted the TRO in part and ordered:
- Respondents shall not remove, transfer, or facilitate the removal of Ijeoma C. from the District of Minnesota.
- No other person or agency shall do so on Respondents' behalf.
- Respondents shall not prevent Ijeoma C. from having necessary access to counsel during the pendency of the petition.
- The TRO is effective immediately and expires fourteen days from entry unless extended for good cause; the court stated it anticipates ruling on the underlying petition within ten days of receiving the government's response.
The court denied the broader requested relief of blocking deportation entirely. The court also waived the bond requirement typically required under Federal Rule of Civil Procedure 65(c), finding no identifiable risk of monetary loss to Respondents and noting the matter involves important public interests, citing Richland/Wilkin Joint Powers Auth. v. U.S. Army Corps of Eng'rs, 826 F.3d 1030, 1043 (8th Cir. 2016).
Attorneys: Kenneth U. Udoibok of Kenneth Ubong Udoibok, P.A., for Ijeoma C.; Ana H. Voss of the United States Attorney's Office, Minneapolis, for the federal Respondents.
Reviewer note from the AI+
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