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 granted in part an emergency request to temporarily block the government from transferring detained Somali immigrant Ali C. out of the District of Minnesota.
Immigrants held in detention in the District of Minnesota who are awaiting resolution of legal challenges to their custody and who fear being transferred to another jurisdiction before their cases are decided.
What happened
In Ali C. v. Bondi (No. 25-CV-4615), Ali C., a Somali national who entered the United States in August 2022, was taken into immigration custody on December 1, 2025, and held at Sherburne County Jail. He had received Special Immigrant Juvenile status and deferred action from removal, and was awaiting eligibility to apply for lawful permanent residence. He filed an emergency motion asking the court to order his release and to stop the government from transferring him out of Minnesota while his case proceeded.
The court weighed the four factors courts use when deciding whether to issue a temporary restraining order: the risk of irreparable harm to Ali C., the balance of harms between the parties, the likelihood that Ali C. would succeed on the merits, and the public interest. The court found that transferring Ali C. out of the district could cause irreparable harm — he might lose access to his lawyer, the court could lose legal authority over the officials detaining him, and he might be unable to participate in his own case. The court found no comparable harm to the government from keeping him in the district temporarily.
Judge Jeffrey M. Bryan granted the motion in part — only as to the transfer restriction, not the release request. The order prohibits all respondents and any other person or agency acting on their behalf from removing or transferring Ali C. from the District of Minnesota. The order took effect immediately and expires in fourteen days unless Ali C. shows good cause to extend it.
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. He obtained Special Immigrant Juvenile (SIJ) classification — a federal immigration status for certain vulnerable young people — and was granted deferred action from removal by the Department of Homeland Security. He was awaiting eligibility to file for lawful permanent residence (a "green card") when, on December 1, 2025, immigration authorities took him into custody. He has since been detained at the Sherburne County Jail in Elk River, Minnesota, under mandatory detention provisions found at 8 U.S.C. § 1225(b)(2). Ali C. contends his detention is unlawful.
On December 16, 2025 — the same day the court issued this order — Ali C. filed an emergency motion for a temporary restraining order (TRO). 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 for a court order challenging his detention (commonly called a habeas petition) was pending.
Legal Standard
A TRO is an emergency court order intended to preserve the status quo until the court can more fully consider the merits of a dispute. Courts in the Eighth Circuit (the federal appeals court covering Minnesota) evaluate four factors drawn from Dataphase Systems, Inc. v. C L Systems, Inc., 640 F.2d 109 (8th Cir. 1981):
- The threat of irreparable harm to the person seeking the order;
- The balance between that harm and any harm an injunction would cause the opposing party;
- The probability that the moving party will succeed on the merits; and
- The public interest.
No single factor is controlling; courts weigh all circumstances to determine whether justice requires preserving the status quo. The party seeking the TRO bears the burden of establishing these factors.
Analysis
Transfer Restriction
The court found that all four factors favored granting the request to prevent Ali C.'s transfer out of the District of Minnesota.
Irreparable harm
If transferred, Ali C. could lose access to his retained attorney, the court could lose jurisdiction (legal authority) over the custodial respondents, and Ali C. might be unable to participate in the litigation. The court characterized these as concrete, imminent injuries that could not be remedied after the fact.
Balance of harms
The court found no indication that respondents would suffer any harm from a temporary prohibition on transferring Ali C. out of the district. This factor weighed heavily in Ali C.'s favor.
Likelihood of success on the merits
The court found that Ali C.'s arguments raise a substantial question about the legality of the terms of his detention, which was sufficient to weigh this factor in his favor at this stage.
Public interest
The court identified preserving access to judicial review and preventing potentially unlawful detention as compelling matters of public importance.
The court cited a similar ruling in Hoque v. Trump, No. 25-CV-1576 (D. Minn. Apr. 22, 2025), in which another judge temporarily enjoined a transfer out of the district while a habeas petition was pending, and quoted Escalante v. Bondi, No. 25-CV-3051 (D. Minn. 2025), for the proposition that losing access to retained counsel is plainly harmful to a litigant.
Release Request
The court did not grant the request for immediate release. The order is silent as to when or whether that portion of the motion will be addressed, but the grant is explicitly only "in part," covering only the transfer restriction.
Bond Requirement
Under Federal Rule of Civil Procedure 65(c), courts granting a TRO typically require the moving party to post a bond (a sum of money to compensate the other side if the TRO is later found to have been wrongly issued). The court waived this requirement because the TRO seeks to prevent constitutional deprivations, because respondents face no identifiable risk of monetary loss, and because the matter is closely associated with important public interests.
Order
Judge Bryan granted in part Ali C.'s Emergency Motion for a Temporary Restraining Order. Specifically:
- Respondents are ordered not to remove, transfer, or otherwise facilitate the removal of Ali C. from the District of Minnesota.
- No other person or agency may remove, transfer, or facilitate Ali C.'s removal from the district on respondents' behalf.
- The order took effect immediately upon entry on December 16, 2025, and expires fourteen days after that date unless Ali C. shows good cause for an extension. If the court determines an extension is necessary, it will set a briefing schedule by separate order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.