A recent federal court filing challenges the actions of U.S. immigration authorities after two asylum seekers were re-detained years after being granted conditional parole, raising questions about due process rights for noncitizens during ongoing immigration proceedings. The complaint was filed by Eliezer Abraham Angarita-Badia and Arouna Ichola Nonvide in the United States District Court for the Western District of Michigan on April 17, 2026, naming Kevin Raycraft, Acting Field Director for U.S. Immigration and Customs Enforcement (ICE) Detroit Field Office; Markwayne Mullin, Secretary of the Department of Homeland Security; and Todd Blanche, Acting U.S. Attorney General as defendants.
According to the document, both plaintiffs arrived at the southern border—Angarita-Badia in July 2022 and Nonvide in January 2025—and were initially detained before being released on their own recognizance under conditional parole. The complaint states that both men demonstrated to Department of Homeland Security (DHS) officials that they were neither flight risks nor dangers to the community at the time of their release.
The central claim in the lawsuit is that both individuals were “randomly re-arrested and re-detained” by ICE agents in March 2026 without any violation of their parole conditions or any new evidence suggesting a change in circumstances. The filing asserts: “Neither Plaintiff violated the terms of their conditional paroles. Their individual asylum cases are still in progress and there has been no order of removal or any other final decision in their cases.” It further alleges that these arrests occurred during non-targeted enforcement operations focused on non-white individuals in certain areas of Michigan believed by ICE to have high populations of foreign-born people.
The plaintiffs contend that no warrants were issued prior to their re-arrests, nor did any authorized DHS officers review or approve revocation of their parole status. The document states: “No one — except the low-level ICE agents who arrested Plaintiffs — made any discretionary decision to revoke the Plaintiffs’ parole or to re-detain them.” Both men are currently held at detention facilities within Michigan—Angarita-Badia at North Lake Processing Center in Baldwin and Nonvide at Calhoun County Jail in Battle Creek—without access to bond hearings.
The legal arguments presented focus on alleged violations of constitutional rights under the Fifth Amendment’s Due Process Clause, relevant federal statutes, and administrative law principles. Citing case law, the complaint argues: “Individuals who have been conditionally released from detention have a protected interest in their ‘continued liberty.'” It maintains that due process requires notice and an opportunity for a hearing before such individuals can be re-detained unless there is evidence justifying revocation based on flight risk or danger.
Additionally, plaintiffs assert that only specific DHS officers are authorized under federal regulations (8 C.F.R. § 236.1(9)) to make decisions regarding parole revocation and subsequent arrest—a procedure they allege was not followed: “None of those authorized officers made any decision regarding the re-arrest of either Plaintiff.” The suit also claims that if any discretionary decision was made by authorized officials, it was arbitrary and capricious because there was no factual basis related to changed circumstances or violations warranting detention.
In terms of relief sought from the court, plaintiffs request several forms of judicial intervention: an injunction preventing transfer from Michigan jurisdiction pending proceedings; declarations affirming their protected liberty interests; findings that defendants violated due process and acted unlawfully; orders for immediate release; prohibitions against future re-arrest without proper cause; attorney’s fees under applicable statutes; and any additional relief deemed appropriate by the court.
The complaint is signed by attorney Michael Drew from Neighborhood Legal, LLC based in Chicago, Illinois. The case is identified as Case No. 1:26-cv-1250.
Source: 126cv1250_Eliezer_Abraham_v_Kevin_Raycraft_Complaint_Western_District_of_Michigan.pdf
