Ijeoma C. v. Bondi

Background

Ijeoma C. is a noncitizen from Nigeria who entered the United States lawfully in 2017. She is the sole caregiver for a child who is a United States citizen. She was convicted on April 19, 2023, in federal court for Conspiracy to Commit International Money Laundering. According to the petition, she provided substantial assistance to the government in connection with her conviction, placing her in danger of retaliation from individuals engaged in fraud schemes who have threatened to kill her if she returns to Nigeria.

Ijeoma C. has multiple immigration applications pending: a Violence Against Women Act (VAWA) petition seeking immigrant classification as an abused spouse of a United States citizen; an application for asylum; an application for withholding of removal to Nigeria; and a request for protection under the Convention Against Torture. She had not yet had interviews or hearings on any of these applications.

On December 4, 2025, U.S. Immigration and Customs Enforcement (ICE) took Ijeoma C. into custody. On December 22, 2025, the Department of Homeland Security issued a Final Administrative Removal Order for her deportation to Nigeria despite her pending applications. During detention, she was not afforded access to counsel.

She filed a petition for a writ of habeas corpus (a court order challenging the lawfulness of detention) on December 23, 2025. The petition challenges her detention and the removal proceedings, arguing she is entitled to a bond hearing or release and that under 8 U.S.C. §§ 1227 and 1231(b)(3) she cannot be removed to Nigeria. On December 30, 2025, she filed an Emergency Motion for a Temporary Restraining Order (TRO) — a short-term emergency court order meant to preserve the situation until a fuller hearing can be held — requesting both a prohibition on her transfer out of the District of Minnesota and a prohibition on her removal to Nigeria.

Legal Standard

Courts in the Eighth Circuit evaluate TRO motions using the four-factor Dataphase test: (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; and (4) the public interest. No single factor is determinative; courts weigh all circumstances to decide whether justice requires preserving the status quo until the merits are decided. The moving party bears the burden of establishing these factors.

Analysis

Irreparable Harm

The court found that transferring Ijeoma C. out of the District would cause irreparable harm — harm that cannot be undone after it occurs. Specifically, she could lose access to her attorney, lose the ability to participate in her own litigation, and her pending applications for asylum, VAWA relief, withholding of removal, and Convention Against Torture protection could be rendered moot. The court also noted that based on the Final Administrative Removal Order, she faces a concrete and imminent risk of deportation to a country where she faces persecution and death threats. The court cited prior district court decisions holding that unlawful detention is a prime example of irreparable harm and that deprivation of access to retained counsel seriously handicaps a litigant's ability to present their case.

Balance of Harms

The court found no indication that the government would suffer any harm from a temporary order prohibiting her transfer while the habeas petition is pending. It cited an Eighth Circuit decision for the proposition that the equities strongly favor an injunction when the challenged action would have an irreversible impact compared to the lack of harm an injunction would presently impose.

Public Interest

The court found that the public interest in due process, judicial review, and the rule of law outweighs any public interest in deporting Ijeoma C. before her habeas petition is reviewed.

Likelihood of Success on the Merits

The court noted that the petition asserts Ijeoma C. is being detained under 8 U.S.C. § 1225(b)(2), which applies to persons seeking admission. Courts across the country have overwhelmingly rejected the government's mandatory-detention interpretation of that statute. The court cited one district court decision noting the government had been told nearly 300 times its mandatory-detention scheme is unlawful. Because the other three factors independently favored granting temporary relief, the court found it did not need to analyze likelihood of success further — though it signaled that Ijeoma C. would likely succeed on this issue.

Bond Requirement

Under Federal Rule of Civil Procedure 65(c), courts typically require a party receiving a TRO to post a security bond. The court waived this requirement, finding that the TRO seeks to prevent constitutional deprivations, that the government faces no identifiable risk of monetary loss, and that the matter is closely associated with important public interests.

Ruling

The court denied the remaining relief requested — including an order directly prohibiting her removal to Nigeria and requiring a bond hearing. The court ordered the government to file an expedited response to the underlying habeas petition by January 5, 2026, and stated it anticipates issuing a decision on the petition within ten days of receiving that response.