Quick Answer: Why the judge suddenly says “no bond” in light of the 2025 BIA bond rulings and no-bond immigration detention

If your loved one was just picked up by ICE in 2025 and the immigration judge said:

“I don’t have jurisdiction to give bond,”

you’re running straight into one of the most important but under-reported shifts in U.S. immigration law.

In 2025, the Board of Immigration Appeals (BIA) issued a trilogy of precedents — including Matter of Yajure-Hurtado, Matter of Q. Li, and Matter of Dobrotvorskii — that radically change who gets a bond hearing:

Many people are now treated as “applicants for admission” detained under INA § 235(b) instead of § 236(a).
Immigration judges lose authority to hold bond hearings for huge categories of detained immigrants.
Longtime residents who entered without inspection (EWI) can suddenly be treated as if they just arrived at the border.

If you want to see these decisions in black and white, they’re published on the Department of Justice Executive Office for Immigration Review (EOIR) site:

Advocates like the Catholic Legal Immigration Network (CLINIC) and the American Immigration Council describe these as decisions that “severely limit” or “virtually eliminate” bond for many undocumented people:

For families, the result is simple and brutal:

No bond hearing.
Months or even years in detention.
The only realistic exit routes are federal habeas, parole, prosecutorial discretion, or massive public pressure.

Herman Legal Group (HLG) has long written about bond and detention in plain English, including:

Now the rules those guides were based on are being quietly rewritten.

The implications of the 2025 BIA bond rulings and no-bond immigration detention are profound for many families.

Before vs. after 2025: how the bond safety valve disappeared

Before 2025: at least a chance at a bond hearing

Under long-standing practice, most ICE detainees in removal proceedings were held under INA § 236(a):

They could ask an immigration judge for a custody redetermination (bond) hearing.
The judge considered traditional factors like those in Matter of Guerra: danger to the community, flight risk, family ties, and defenses to removal.
If bond was granted, families could try to post it and bring their loved one home while the case continued.

TRAC (Transactional Records Access Clearinghouse) at Syracuse University has tracked these hearings for years:

TRAC Immigration – Detention Quick Facts
TRAC Immigration – Immigration Court Bond Decisions (see “Immigration Court Bond Decisions”)
Using TRAC’s Bond Hearing Tool

Even though bonds were often high, families at least had a day in court.

After 2025: mandatory detention by relabeling

The 2025 BIA trilogy changes the starting presumption.

Using the BIA’s own language and analyses by CLINIC and the American Immigration Council:

People who entered without inspection (EWI) or are treated as “arriving aliens” can be reclassified as “applicants for admission” under § 235(b).
Once labeled § 235(b), they are in mandatory detention and cannot seek bond from an immigration judge.
The only “release” mechanisms are ICE parole or federal litigation.

Key external explainers:

In human terms:

A father who crossed 15 years ago and has U.S. citizen children can now be treated as if he just arrived at the border, with no bond option.
A college student with a pending asylum case can be locked up for months while appeals drag on, even with no criminal record.

HLG has already started mapping this “war on discretion” in resources like:

The 2025 BIA bond rulings and no-bond immigration detention in one table

Multiple nonprofits refer to these as the “three bond decisions” of 2025:

Here’s how they fit together for families:

Case (2025)	Who it targets	What it does	Real-world impact
Matter of Q. Li	Many people classified as “arriving aliens” at ports of entry or soon after entry	Treats them as detained under INA § 235(b) instead of § 236(a), so no IJ bond authority	Asylum seekers and new arrivals remain in mandatory detention, with release only through ICE parole
Matter of Yajure-Hurtado	People present in the U.S. without admission (EWI), even for many years	Re-labels them as “applicants for admission” held under § 235(b); IJs have no power to hold bond hearings	Longtime residents with families are suddenly told the judge “lacks jurisdiction” for bond
Matter of Dobrotvorskii	Those still under § 236(a)	Raises the bar for bond, emphasizing documentation, sponsors, and DHS challenges	Even for those who still qualify, bond becomes rarer and more fragile

For a more technical breakdown, defense lawyers and researchers can cross-check:

How civil detention becomes a “mini life sentence”

On paper, immigration detention is civil, not criminal. In practice:

According to TRAC’s Immigration Detention Quick Facts, ICE held over 65,000 people in detention in November 2025, with roughly three-quarters having no criminal conviction.
The American Immigration Council reports that the average length of detention climbed from 47 days to around 50 days between FY 2024 and mid-2025 — with many asylum seekers, cancellation applicants, and appellants confined months or years while fighting their cases. See: Immigration Detention in the United States by Agency.
A growing number of deaths and medical crises in ICE custody are documented by the American Immigration Council, AILA, and media outlets like the Migration Policy Institute, American Immigration Council’s detention reports, and MPI’s “U.S. Immigrant Detention Grows to Record”.

The official ICE view of this system is laid out here:

But watchdogs and journalists paint a darker picture, including:

HLG has been tracking this escalation in:

Once bond is taken off the table, detention itself becomes the main punishment — even before there’s any final decision on deportation.

The Ohio / Midwest detention pipeline under the new rules

For our core communities in Cleveland, Columbus, Akron, Youngstown, Dayton, Toledo, Cincinnati, and across Ohio, the 2025 bond rulings collide with a regional detention infrastructure built on county jails and private contracts.

Key pieces of the map:

County jails with ICE contracts
- Local reporting (for example, Axios Cleveland’s coverage of Geauga County) shows that the Geauga County Jail holds dozens of ICE detainees per day.
- Other Ohio facilities, including Butler County and Seneca County, are also part of the ICE network. A national list appears on the ICE site at Detention Facilities, and a broader overview is available via USA.gov’s “Detained by ICE” page.
Private prison expansion
- Nationally, ICE is reopening and expanding large contract facilities, often through no-bid or emergency contracts with corporations like GEO Group and CoreCivic. See, e.g., AP’s reporting on no-bid detention contracts and coverage of the new mega-facility in Newark: “ICE to open East Coast’s largest federal immigration detention center in Newark” – New York Post.
Transfers far from home
- The combination of local jails and national private facilities means a person picked up in Cleveland or Columbus can rapidly end up in a distant state, effectively cut off from family and local counsel.

For Ohio families trying to navigate this, HLG has built practical guides:

When you overlay the 2025 “no bond” rulings onto this infrastructure, routine civil cases begin to look and feel like open-ended confinement by design.

What families can still do when the judge says “no bond”

Even after the 2025 trilogy, families are not powerless. But the options are more complex and litigation-heavy.

1. Federal habeas corpus in U.S. district court

Habeas petitions ask federal judges to review whether detention is:

Statutorily lawful under the INA, and
Constitutionally permissible when it becomes prolonged without a realistic chance of removal.

Practice advisories and amicus briefs from groups like the American Immigration Council, ACLU, and National Immigration Law Center (NILC) show emerging strategies:

In many § 235(b) “no bond” cases, habeas has become the only realistic route to a neutral judge capable of ordering release.

2. ICE parole and humanitarian release

Even when an IJ cannot set bond, ICE retains authority to grant parole in:

Urgent humanitarian cases (serious illness, disability, pregnancy, etc.)
Situations where release is clearly in the public interest.

Strong parole packets typically include:

Detailed medical records
Proof of family and community ties
A specific release plan (address, sponsor, transportation to court)

The official framework is invisible to most families but is hinted at in DHS and ICE materials:

CLINIC’s enforcement materials and FAQs also discuss how parole and similar tools are being used in the Trump era:

Frequently Asked Questions on Trump Administration Policies – CLINIC

HLG’s own rights guides give families a roadmap for engaging with ICE while protecting themselves:

3. Prosecutorial discretion (PD) and negotiated outcomes

Even in a crackdown environment, some Office of Principal Legal Advisor (OPLA) attorneys will consider:

Terminating or dismissing removal proceedings
Joining motions to reopen and close cases
Not opposing parole or humanitarian release in extreme situations

Legal and advocacy organizations have consistently pushed DHS to use PD to reduce unnecessary detention, especially for:

Parents of U.S. citizen children
People with serious medical conditions
Survivors of crime and trafficking

HLG’s strategy guides help families and journalists understand what PD looks like in 2025:

4. Classic bond motions where eligibility still exists

Not everyone is swallowed by § 235(b). Some people remain in § 236(a) detention and can ask for bond.

For them, the fundamentals matter more than ever:

File a detailed Motion for Bond Determination.
Include a robust sponsor packet (proof of lawful presence, stable housing, and income).
Provide extensive evidence of:
- Rehabilitation
- Long-term residence and community ties
- Strong defenses to removal

For background and persuasive framing, lawyers can blend:

Building a “release dossier” families can use in any strategy

Regardless of the legal route, families can start building a “release dossier” on day one. This can be used for:

Habeas
Parole
PD requests
Bond motions

Identity and ties

Passports, national IDs, consular IDs
Marriage certificates and children’s birth certificates
Proof of time in the U.S.:
- Leases, utility bills
- Tax returns and pay stubs
- School records and report cards

Community support

Letters from:
- Employers and supervisors
- Faith leaders
- Teachers and coaches
- Neighbors and community organizations

Medical and vulnerability evidence

Diagnoses and treatment plans from medical providers
Mental health evaluations documenting harm from detention
Records of:
- Disability or chronic illness
- Special-needs children or elderly relatives who depend on the detained person

HLG’s detention and cost-focused pieces give context to why these details matter so much:

Seven-day action plan after a “no bond” decision

This is a practical checklist families can follow.

Day 1–2: Find your loved one and stabilize

Use the ICE Online Detainee Locator System via USA.gov’s “Detained by ICE” page.
Confirm:
- A-Number
- Detention facility
- Next court date

Connect with counsel immediately. HLG has deep roots in Ohio and the Midwest:

Day 3–4: Identify detention authority and legal path

With an attorney:

Confirm whether your loved one is detained under § 235(b) or § 236(a).
Map which strategies are realistic:
- Bond motion
- Habeas petition
- Parole request
- PD request

Begin assembling the release dossier (identity, ties, medical, community support).

Day 5–7: Start executing the strategy

If bond is possible:
- File a Motion for Bond Determination with full evidence, not a bare-bones request.
If bond is barred:
- Begin drafting habeas or a detailed parole packet.
Consider:
- Contacting reputable journalists or advocacy groups, especially in cases involving children, serious medical issues, or systemic abuses.

Resources for navigating the court landscape:

For journalists and researchers: under-reported angles and data wishlist

This topic is tailor-made for high-impact investigative and data journalism.

Data angles

Use TRAC’s tools to compare:
- Number of bond hearings and grant rates before vs. after 2025:
  - TRAC Immigration – Detention Quick Facts
  - TRAC Immigration Tools – Immigration Court Bond Decisions
Pair with American Immigration Council fact sheets:
- Immigration Detention in the United States by Agency
- Alternatives to Immigration Detention: An Overview

Questions to ask:

How many people held in Ohio, Michigan, Pennsylvania and nearby states in 2025 are in “no bond” status?
How has the average length of detention changed since the BIA decisions?
What proportion of detainees in your state have no criminal convictions?

Accountability angles

What internal memoranda did EOIR issue to immigration judges about Yajure-Hurtado, Q. Li, and Dobrotvorskii?
How has ICE’s use of short-term “hidden” detention sites changed since 2025? (See The Guardian’s investigation of secretive ICE holding facilities).
How much money are county jails and private prisons earning from ICE contracts, and how do bed quotas shape local law enforcement behavior? (See ICE Detention Facility List and local reporting like Axios Cleveland on Geauga County Jail).

HLG’s site is built to be a curation resource journalists can quote and link:

Frequently Asked Questions: 2025 BIA Bond Rulings, “No Bond” Detention, and Your Options

1. Why did the immigration judge say they “have no jurisdiction” to give my loved one a bond?

In many 2025 cases, DHS is now claiming your loved one is detained under INA § 235(b) as an “applicant for admission” — not under § 236(a), which is the usual bond statute.

Because of BIA cases like Matter of Yajure-Hurtado and Matter of Q. Li, immigration judges are being told they cannot hold a bond hearing at all for people treated as “arriving” or as EWI entrants detained under § 235(b). In these situations, the judge is not saying “I don’t want to give a bond”; they are saying “I am not legally allowed to give one.”

That is why a lawyer’s first job now is to analyze which statute DHS is using to justify detention, and whether that classification can be challenged.

2. My loved one has been in the U.S. for 10+ years with no criminal record. Can they still be treated like an “arriving alien” with no bond?

Disturbingly, yes — that is exactly what the 2025 BIA decisions enable.

Under Matter of Yajure-Hurtado, people who entered without inspection (EWI) and have lived in the U.S. for years can be re-labeled as “applicants for admission” when they are picked up by ICE. That label triggers § 235(b) mandatory detention, which is supposed to apply at ports of entry and border situations, but is now being stretched into the interior.

The legality of this approach is heavily contested. Practice advisories from groups like the American Immigration Council and CLINIC argue that this interpretation violates both the text and structure of the immigration laws. But until federal courts resolve those challenges, DHS will keep using this theory to block bond in many EWI cases.

3. If there’s no bond, is my loved one stuck in detention until they’re deported?

Not necessarily — but the path to release is much harder than a normal bond motion.

In “no bond jurisdiction” cases, the main tools are:

Federal habeas corpus (asking a federal judge to rule that detention is unlawful or unreasonably prolonged)
ICE parole (discretionary release for humanitarian or public-interest reasons)
Prosecutorial discretion (DHS attorneys agreeing to dismiss, close, or otherwise resolve the case in a way that reduces detention)
In rare situations, class-action or impact litigation

These strategies require:

An experienced attorney
Strong documentation of family ties, health, and defenses to removal
Patience and persistence — these are not quick fixes, but they are often the only real options when bond is off the table.

4. How do I know if my family member is detained under § 235(b) or § 236(a)?

You cannot assume from the paperwork alone; you need to dig.

A good attorney will:

Read the Notice to Appear (NTA) and any custody paperwork
Listen carefully to what DHS and the judge say on the record at the initial hearing
Compare your loved one’s situation against the fact patterns in:
- Matter of Q. Li
- Matter of Yajure-Hurtado
- Matter of Dobrotvorskii

If the government insists the person is under § 235(b) and therefore “no bond eligible,” your lawyer can assess whether to:

Argue that § 236(a) actually applies, or
Move straight into habeas and/or parole strategy

This is not a “form-filling” question; it’s a serious statutory analysis that can completely change the outcome of a case.

5. Is there any time limit on how long ICE can hold someone with no bond?

There is no automatic time limit in § 235(b). That is the core danger.

However:

The Supreme Court has warned (in cases like Zadvydas v. Davis and Jennings v. Rodriguez) that indefinite, unreviewed detention raises serious constitutional problems.
Federal courts around the country have started granting habeas petitions when:
- Detention becomes “unreasonably prolonged,” and
- The person has no realistic chance of removal in the near future, or there are serious legal disputes about the detention statute.

So while there is no clean “6-month” or “12-month” deadline written in the statute, the longer someone sits in detention with no progress, the stronger habeas arguments can become.

6. My loved one has serious health issues. Does that matter in a no-bond case?

Yes — health is one of the most powerful levers in parole, habeas, and PD.

In many cases, the single most persuasive factor for ICE and federal judges is a combination of:

Evidence that the person has serious medical or mental health conditions
Proof that the detention facility cannot or will not provide adequate care
Documentation that release to family and community would dramatically improve safety and treatment

A strong health-based release package usually includes:

Specialist letters, hospital discharge summaries, and medication lists
Psychological evaluations that tie detention to worsening symptoms
Evidence of concrete plans for treatment outside (appointments, insurance, clinic letters)

Many habeas petitions are built around medical vulnerability and inhumane conditions, especially when combined with the “no bond” framework.

7. What if my detained relative has old or minor criminal charges? Does that automatically destroy their chances?

Not automatically — but it changes the analysis.

There are three overlapping layers:

Detention statute
- Certain convictions may trigger mandatory detention under § 236(c) (separate from the 2025 bond trilogy).
- Others may still be under § 236(a) (bond-eligible) or § 235(b) (no bond).
Bond / release risk factors
- Even when bond is technically allowed, criminal history can drive judges to:
  - Set very high bond amounts, or
  - Deny bond outright.
Relief on the merits
- Past convictions may limit eligibility for:
  - Cancellation of removal
  - Certain waivers
  - Naturalization in the future

However, even with a record, carefully documented:

Rehabilitation
Sober time
Family responsibilities
Stable employment

can make a significant difference in PD, parole, and, where still available, bond.

8. We live in Ohio. Does that make our case different?

It can, in several ways:

Ohio sits in circuits and regions where ICE and EOIR are under intense political and budget pressure to detain more people.
Many detention beds in Ohio are in county jails (Geauga, Butler, Seneca) and nearby private prisons that run on per-bed contracts with ICE.
Transfers out of state — for example, to large GEO or CoreCivic facilities — are common.

This means:

The local “culture of detention” may be more aggressive than in some coastal jurisdictions.
Decisions about parole and PD can vary significantly by ICE field office and OPLA leadership.
Local media and advocacy campaigns can have outsized impact because facilities are often located in smaller communities that are sensitive to scrutiny.

HLG’s Cleveland Immigration Court 2026: Complete Survival Guide and Midwest Deportation Defense Organizations and Legal Strategies are designed specifically for this landscape.

9. My loved one is an LPR (green card holder). Are they affected by these “no bond” rulings?

Less directly, but they’re still impacted by the overall shift.

Most LPRs in detention are held under:

§ 236(c) (mandatory detention for certain criminal grounds), or
§ 236(a) (if they do not fall under mandatory detention).

The 2025 bond trilogy is aimed mainly at “arriving” and EWI noncitizens, but:

It contributes to a system-wide culture where detention is normalized and judicial discretion shrinks.
It can influence how judges think about danger and flight risk, even when bond technically exists.
It makes ICE and OPLA less willing to agree to PD for anyone, including LPRs.

So even if your LPR loved one is not technically “no bond,” they may face higher bonds, more detention, and more resistance than in prior years.

10. How do these rulings affect asylum seekers?

Asylum seekers are hit particularly hard because:

Many are classified as “arriving aliens” or placed into expedited removal.
Under the BIA decisions, judges often cannot give bond at all in these cases.
Credible-fear interviews, asylum applications, and appeals can take months or years.

This means asylum seekers can find themselves:

Stuck in mandatory detention while fighting complex legal cases
Working with limited access to lawyers, interpreters, and evidence
Vulnerable to coercive pressure to give up their claims simply to escape jail-like conditions

Advocacy resources like the American Immigration Council’s asylum and detention page and CLINIC’s bond and enforcement materials offer deeper background on how this plays out on the ground.

11. Is there anything my family can do before my loved one is detained?

Yes. Some of the most powerful steps are preventive, not reactive:

Legal screening for everyone in the household, especially:
- People with prior entries without inspection
- People with prior orders of removal
- Those with pending asylum or old criminal cases
Safety planning:
- Decide who will call the attorney if someone is detained
- Gather key documents in one place (IDs, marriage/birth certificates, medical records)
- Make sure at least one trusted person knows A-numbers, case numbers, and passwords
Know-your-rights training:
- Everyone should understand the basics in case of a knock on the door or a traffic stop.
- HLG’s ICE Came to My Door: What Are My Rights? is a good starting point.

Preventive planning cannot guarantee safety, but it can make the difference between weeks of confusion and a rapid, coordinated response.

12. My loved one’s case has strong relief (asylum, cancellation, marriage-based). Does that help with detention?

Yes — if it’s presented well.

Even in a no-bond world, relief on the merits is central to:

Habeas arguments
Parole / PD requests
Any discretionary decisions DHS has to make

The government (and judges) are more likely to consider release when:

There is a clear, legally viable path to permanent status or protection; and
The evidence is organized and compelling (country conditions, hardship, equities, rehabilitation).

That’s why HLG often treats relief development and detention strategy as a single integrated project, not two separate cases.

13. Can my loved one be transferred far away even if we hired a local lawyer?

Yes — and it happens all the time.

ICE has broad power to transfer detainees between facilities, often with:

Little notice to families
Confusing or inaccurate information
Major obstacles to attorney access

Transfers can:

Disrupt attorney–client communication
Make it harder to gather evidence and witnesses
Increase the pressure to give up and sign for removal

Because of this, many habeas petitions and advocacy campaigns emphasize the harm of long-distance transfers, especially when bond is already off the table.

14. What role can journalists and media play in no-bond detention cases?

Media coverage is not a substitute for legal strategy, but it can:

Increase pressure on ICE and local jails to use parole and PD
Expose unsafe conditions, medical neglect, or abuse
Highlight patterns:
- County jails profiting off detention
- Disparate impact on specific communities or nationalities
- “No bond” policies effectively turning civil cases into indefinite confinement

Journalists often need:

A human story (with consent and careful safety assessment)
Documents (court filings, medical records, facility reports)
Reliable experts to quote

HLG’s long-form explainers, like New Record: ICE Detainee Population Reaches High of 2025 and Deportation Judges: Inside the 2025 Immigration Court Crackdown & Due Process Crisis, are designed to be source material that journalists can cite and link.

15. Are there special risks for people from certain countries or regions?

In practice, yes.

Even though the law is supposed to be neutral, enforcement patterns often place particular groups at higher risk of:

Arrest
Mandatory detention
Denial of parole
Background check delays (e.g., “security checks” that drag for months)

These patterns change over time depending on:

Foreign policy
Domestic politics
Media narratives

For example, people from countries labeled “high risk” in travel bans, terrorism lists, or “special registration” programs often face extra scrutiny and tougher detention decisions, even when they have strong relief.

This is yet another reason why country of origin, manner of entry, and political context must all be analyzed in detention strategy.

16. Can my loved one still work or get a work permit while detained or after release?

While detained, your loved one generally cannot work lawfully in the U.S. in any normal sense.

After release:

Work authorization depends on what kind of case is pending:
- Asylum applicants may qualify for an EAD after certain waiting periods.
- Some people in family-based or employment-based processes may qualify for work permits.
- Others may not have any work authorization at all until a specific application is filed and approved.

Detention and “no bond” status can delay or complicate work authorization by:

Slowing down case filing
Making it harder to gather evidence
Interrupting status or eligibility timelines

HLG often pairs a detention plan with a post-release work authorization strategy, especially for breadwinners with U.S. citizen families.

17. What if my loved one is LGBTQ+, disabled, or otherwise especially vulnerable?

These vulnerabilities are extremely important — both for safety and for release arguments.

In detention, LGBTQ+ people, disabled adults, and others with special vulnerabilities face heightened risk of:

Violence and harassment
Medical neglect
Isolation and mental health deterioration

In many cases, this can be used to support:

Parole requests (urgent humanitarian grounds)
Habeas petitions arguing that continued detention violates due process and basic human rights
Media coverage highlighting systemic abuse

Families and advocates should document these vulnerabilities early and thoroughly, and consider connecting with specialized organizations (LGBTQ+ immigrant groups, disability rights orgs, etc.) alongside legal counsel.

18. Can we change immigration judges or courts if ours seems extremely harsh?

Immigration court jurisdiction is based on:

Where the Notice to Appear is filed
Where the detention facility is located
Specific EOIR and ICE internal rules

Families cannot simply choose a new judge, but sometimes:

Transfers between facilities or
Changes in ICE or EOIR policy

can move cases between courts or judges.

However, this is not something families can control. Instead of hoping for a friendlier judge, it’s usually more effective to:

Build the strongest factual and legal record possible
Consider federal court review (habeas or petitions for review) where appropriate

19. Does it ever make sense to “take the deportation” just to end detention?

This is the hardest question many families face.

Accepting removal can:

End detention in the short term, but
Create permanent bars or long-term bans on returning to the U.S.
Trigger life-changing consequences for U.S. citizen spouses and children
Put the person at risk of persecution, torture, or severe hardship in their home country

Before making any decision like this, it is essential to:

Get a full legal analysis of all possible relief (asylum, withholding, CAT, cancellation, waivers, family-based options)
Weigh the long-term risks against the short-term pain of detention
Consider whether habeas, parole, or PD offer realistic ways to end detention without giving up on the case

HLG’s approach is to exhaust every reasonable legal and humanitarian option before anyone consents to removal.

20. When should our family contact Herman Legal Group about a no-bond detention case?

If:

The judge has said they “lack jurisdiction” to give bond, or
ICE is insisting your loved one is a § 235(b) detainee, or
Detention has already lasted months with no clear exit path,

you should reach out as soon as possible.

Herman Legal Group can:

Analyze the detention statute and how the 2025 BIA rulings apply
Develop a release strategy: habeas, parole, PD, or (where possible) bond
Coordinate with medical providers, community groups, and journalists where appropriate
Build a relief roadmap so detention strategy and long-term immigration goals stay aligned

You can start by booking a confidential consultation or visiting our Ohio locations page to connect with a local office.

The earlier you act, the more leverage you may have to challenge a civil detention system that increasingly looks like a life sentence in disguise.

Follow the Money: How “No Bond” Detention Became a Business Model

One reason the 2025 bond rulings slid under the radar is that they plug almost perfectly into an existing detention business model built around:

Per-bed contracts between ICE and local jails
Long-term contracts with private prison corporations
A political narrative that rewards “toughness” measured in headcounts, not outcomes

Every person who is denied a bond hearing becomes:

A reliable “bed filled” for a county jail or private contractor
A line item in ICE’s detention budget
An invisible statistic inside the bureaucracy, far from cameras

Groups like TRAC Immigration and the American Immigration Council have shown how detention numbers and costs have exploded over the past decade. At the same time, investigative outlets and NGOs have documented how:

County jails in rural areas become financially dependent on ICE per-diem payments
Private companies like GEO and CoreCivic seek multi-year detention contracts insulated from public oversight
The line between “civil” immigration detention and for-profit incarceration gets thinner every year

When judges lose bond authority because of Yajure-Hurtado, Q. Li, and Dobrotvorskii, that doesn’t just affect due process. It helps lock in a revenue stream:

Fewer people released on bond → more full beds
More full beds → stronger argument to maintain or expand contracts
More contracts → more political pressure to keep “no bond” rules in place

If you follow the money, “no bond jurisdiction” looks less like a technical legal tweak and more like the perfect legal fuel for an already booming detention industry.

You can see the fiscal side in resources like:

For journalists and policy analysts, this section opens up an obvious but under-reported question: Whose budgets and profit statements depend on “no bond” detention staying the norm?

DIY Detention Data Lab: How Families and Advocates Can Turn One Case into a Community Evidence Project

Most families feel completely powerless when someone they love is taken with no bond option. One way to fight back, beyond the individual case, is to turn that pain into data and documentation the system can’t ignore.

This section gives readers a concrete way to build a “DIY Detention Data Lab” at the community level — the kind of project that reporters, researchers, and NGOs will want to link to.

Step 1: Start a local detention log

Begin with a simple shared spreadsheet (Google Sheets, privacy-safe alternatives, etc.) and track:

Initials or pseudonyms (not full names, for safety)
Date and place of arrest
Detention facility (county jail, private prison, out-of-state transfer)
Whether the judge said “no jurisdiction” over bond, or denied bond on the merits
Family situation (U.S. citizen kids, serious health issues, caregiver roles)
Case type (asylum, cancellation, old removal order, marriage-based case, etc.)

Over time, this becomes a community-level snapshot of how “no bond” is being used in your state.

Step 2: Cross-reference with national data

Use publicly available tools to layer local data onto national trends:

Ask:

Is your local detention pattern harsher than national averages?
Are certain nationalities or neighborhoods disproportionately represented?
Do bond denials (where bond still exists) look more severe in your city or court?

Step 3: Turn the log into a story engine

Once the log has dozens of entries, it becomes raw material for:

Media stories (local papers, TV, national outlets)
FOIA requests about contracts, policies, and outcomes
Research collaborations with law schools or university labs
Advocacy campaigns focused on specific jails or ICE field offices

HLG’s policy-facing articles are written to plug into exactly this kind of bottom-up evidence:

A local detention log isn’t just a spreadsheet. It’s a shadow report on how “no bond” detention is actually working in your city — and a magnet for journalists and researchers looking for real-world data and stories.

The Back-Room Paper Trail: FOIA Questions and Internal Memos Journalists Should Be Demanding

Most coverage of immigration detention focuses on raids, protests, and heartbreaking individual stories. Far fewer reporters ask: What’s in the back-room memos that made “no bond” inevitable?

This section gives journalists, watchdog groups, and public-records nerds a ready-made FOIA and records-request checklist. It’s the kind of “meta resource” that tends to attract backlinks from newsrooms, press-freedom organizations, and academic researchers.

1. EOIR training and guidance on the 2025 bond trilogy

Questions to ask through FOIA or public-records requests:

What training materials or slide decks did EOIR circulate to immigration judges explaining how to apply:
- Matter of Q. Li
- Matter of Yajure-Hurtado
- Matter of Dobrotvorskii?
Did EOIR track:
- Changes in bond-hearing numbers
- Changes in grant/denial rates
- Regional differences between courts?

Tie this to public EOIR sources like:

2. ICE field-office guidance on parole and “no bond” cases

Key FOIA angles for ICE and DHS:

What written guidance do field offices have on parole for:
- Asylum seekers
- Parents of U.S. citizen children
- People with serious medical conditions?
Did ICE issue internal memos after the BIA decisions instructing officers:
- How to classify more people under § 235(b)?
- How to respond to parole and release requests in “no bond” cases?

Public starting points:

3. County and private prison contracts: who profits from “no bond”?

Local reporters and watchdogs can request:

Full text of ICE–county jail contracts (including per-diem rates and bed guarantees)
Amendments or renewals after the 2025 BIA decisions
Communications between:
- County sheriffs and ICE
- Private prison lobbyists and state/local officials

These requests can be paired with detention facility lists and public information like:

HLG’s detention-cost explainer

Recent Statistics: ICE Arrest, Detention & Removal Costs – What Are the Figures?

Resource directory: primary sources and expert organizations

Government and courts

Data and research

Non-profits and advocacy groups

Herman Legal Group deep dives

Call to action: if your loved one is detained with “no bond” in Ohio or the Midwest

If your spouse, parent, child, or friend is locked in Geauga, Seneca, Butler, Youngstown, or any ICE-contract facility, and the judge has said there is no power to grant bond, you still have options.