Johnson v. Arteaga-Martinez

Antonio Arteaga-Martinez, a Mexican national facing removal, was detained by ICE for over four months without a bond hearing. He filed a habeas corpus petition, arguing that under the Immigration and Nationality Act, prolonged detention required a bond hearing to determine dangerousness or flight risk. The District Court and Third Circuit agreed, ordering the government to provide a bond hearing after six months. The Supreme Court reversed, holding that the statute's text does not mandate such a hearing. The Court ruled that lower courts cannot impose procedural requirements like bond hearings where Congress had not authorized them, emphasizing that the statutory scheme focuses on detention while removal proceedings are ongoing.

The Supreme Court reversed the Third Circuit. In an 8-1 decision, it held that the Immigration and Nationality Act does not require a bond hearing for prolonged detainees seeking to prevent removal. Justice Breyer dissented in part.

Whether the Immigration and Nationality Act requires the government to provide a bond hearing to noncitizens detained for six months to assess dangerousness or flight risk.

The ruling significantly limits procedural due process rights for noncitizens in prolonged detention, affirming the executive branch's broad power to detain individuals during removal proceedings without mandatory judicial oversight. It was criticized by immigrant rights groups for potentially enabling indefinite detention without prompt judicial review.