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
Counsel of record per CourtListener. Firm names are approximate.
In Ali C. v. Bondi, Judge Bryan temporarily blocked immigration officials from transferring a detained Somali immigrant out of the District of Minnesota while his detention challenge proceeds.
Non-citizens held in immigration detention in the District of Minnesota who have pending legal challenges to their detention, particularly those with Special Immigrant Juvenile status or deferred action, who face the risk of being transferred out of the district before their cases are resolved.
What happened
In Ali C. v. Pamela Bondi et al., No. 25-CV-4615, a Somali national who entered the United States in August 2022 was taken into immigration custody on December 1, 2025, and held at the Sherburne County Jail in Elk River, Minnesota. He had received Special Immigrant Juvenile status and had been granted deferred action from removal while awaiting eligibility to apply for lawful permanent residence. He filed an emergency motion asking the court both to order his release and to prevent his transfer out of the District of Minnesota while his case proceeds.
The court applied a four-factor test used for temporary restraining orders, weighing: (1) the risk of irreparable harm to the person seeking the order; (2) the balance of harms between the parties; (3) the likelihood of success on the underlying legal claim; and (4) the public interest. The court found that transferring Ali C. out of the district could cause him to lose access to his attorney, could deprive the court of authority over the officials holding him, and could prevent him from participating in his own case — all harms that cannot be undone after they happen. The court also found that his arguments raise a substantial question about whether his detention is lawful.
Judge Jeffrey M. Bryan granted the motion in part, ordering that government officials may not move Ali C. out of the District of Minnesota, effective immediately. The court declined to order his release at this time. The order expires in fourteen days unless Ali C. shows good cause to extend it. The court also waived the bond requirement that typically accompanies such orders, finding that the case involves potential constitutional deprivations, that the government faces no identifiable monetary loss, and that the matter is closely tied to important public interests.
The detailed version
- Ali C. v. Bondi · No. 0:25-cv-04615
- Jeffrey M. Bryan
- Dec. 16, 2025
Background
Petitioner Ali C. is a citizen and national of Somalia who entered the United States in August 2022 and has resided here since. He obtained Special Immigrant Juvenile (SIJ) classification — a federal immigration status available to certain minors 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 to temporarily refrain from deporting him. He was awaiting eligibility to file an application for lawful permanent residence (a "green card").
On December 1, 2025, immigration officials took Ali C. into custody. He has been held at the Sherburne County Jail in Elk River, Minnesota since that date. U.S. Immigration and Customs Enforcement (ICE) is detaining him pursuant to 8 U.S.C. § 1225(b)(2), which governs mandatory detention of certain arriving aliens. Ali C. contends that his detention under that provision is unlawful.
Procedural Posture
On December 16, 2025 — the same day as this order — Ali C. filed an emergency motion for a temporary restraining order (TRO), a short-term court order designed to preserve the status quo until a fuller hearing can be held. He sought two forms of relief: (1) an order requiring his immediate release from custody; and (2) an order prohibiting respondents from transferring him out of the District of Minnesota while his underlying petition — a challenge to the legality of his detention — remains pending.
The respondents named are: Pamela Bondi (Attorney General), Kristi Noem (Secretary of DHS), Todd M. Lyons (Acting Director of ICE), Sam Olson (Field Office Director of the Fort Snelling ICE Field Office), and David Isais (Jail Commander, Sherburne County Jail). All were represented by the United States Attorney's Office for the District of Minnesota. Ali C. is represented by counsel from a private law office.
Legal Standard for a Temporary Restraining Order
The court applied the four-factor Dataphase test from the Eighth Circuit Court of Appeals, which evaluates: (1) the threat of irreparable harm to the moving party; (2) the balance of harms between the parties; (3) the probability that the moving party will succeed on the merits of the underlying claim; and (4) the public interest. No single factor is controlling; courts weigh all circumstances flexibly. The central inquiry is whether preserving the status quo is necessary until the merits can be resolved. The moving party bears the burden of establishing these factors.
Analysis and Holding
The court found that the factors, on the record before it, weigh in favor of granting the non-transfer portion of Ali C.'s motion.
Irreparable Harm
The court identified three concrete, imminent harms that would result from transferring Ali C. out of the district: (1) he could lose access to his retained counsel; (2) the court itself could lose jurisdiction — that is, legal authority — over the custodial respondents if Ali C. is moved beyond the district; and (3) Ali C. could be effectively prevented from participating in his own litigation. The court noted that while access to counsel is not a constitutional right in civil proceedings, deprivation of retained counsel is plainly harmful because it handicaps a litigant's ability to present his case. These harms, the court concluded, are irreversible once they occur.
Balance of Harms
The court found no indication that respondents would suffer any harm from a temporary order prohibiting transfer. It cited a prior decision from the same district, Hoque v. Trump (D. Minn. 2025), and an Eighth Circuit decision, Nebraska v. Biden (2022), for the proposition that the equities strongly favor an injunction when the impact on the moving party is irreversible and the harm to the opposing party is nonexistent or minimal.
Likelihood of Success on the Merits
The court stated that Ali C.'s arguments raise a "substantial question" about the legality of the terms of his detention. The court did not elaborate further on the merits of the underlying habeas challenge at this stage.
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.
Disposition
Judge Bryan granted the motion in part. The court issued a TRO ordering that:
- Respondents shall not remove, transfer, or otherwise facilitate the removal of Ali C. from the District of Minnesota.
- No other person or agency shall do so on respondents' behalf.
- The order is effective immediately and expires fourteen days after entry unless Ali C. shows good cause for extension, in which case the court will set a briefing schedule by separate order.
The court denied the motion as to the request for immediate release — that relief was not granted.
Bond Waiver
Federal Rule of Civil Procedure 65(c) ordinarily requires a party obtaining a TRO to post a security bond to compensate the opposing party if the order turns out to have been wrongly issued. The court waived this requirement, finding: (1) the TRO seeks to prevent potential constitutional deprivations; (2) respondents face no identifiable risk of monetary loss; and (3) the matter is closely associated with important public interests, citing Richland/Wilkin Joint Powers Auth. v. U.S. Army Corps of Eng'rs (8th Cir. 2016).
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.