A federal judge in West Virginia has issued a stern warning to officials, stating that continued illegal detentions by Immigration and Customs Enforcement will lead to contempt proceedings and sanctions without qualified immunity. The ruling comes in a habeas corpus case involving Miguel Antonio Dominguez Izaguirre, whose detention was deemed a violation of due process rights. This decision highlights ongoing judicial rejections of the government's interpretation of immigration detention laws.
U.S. District Judge Joseph R. Goodwin, appointed by Bill Clinton, ruled in favor of petitioner Miguel Antonio Dominguez Izaguirre, a Honduran man who entered the United States in 2016 and resides in Cana, Virginia, with his two young U.S. citizen children. Dominguez Izaguirre was arrested by ICE agents on February 14, 2026, while traveling near Summersville, West Virginia, and detained without criminal charges or a custody hearing. His attorneys filed a habeas corpus petition on February 19, 2026, arguing that the detention violated his Fifth Amendment due process rights.
Goodwin ordered the petitioner's immediate release, noting that "Petitioner's due process rights have been violated" and that "immediate release is the only appropriate remedy." This case is part of a broader pattern in the West Virginia federal district, where judges have consistently rejected the Trump administration's claim that ICE can mandatorily detain immigrants under 8 U.S.C. §1225(b), which applies to those seeking entry. Instead, courts have applied 8 U.S.C. §1226(a), governing those already present in the U.S., following interpretations from a 2018 Supreme Court ruling by Justice Samuel Alito.
The opinion highlights that this is the 17th such petition assigned to the court that week, with the government's arguments rejected unanimously in the district—on February 4, twice on February 5, February 9, and February 11, 2026, by four different judges. Goodwin expressed frustration, stating, "Today, the Government continues to wrongfully detain those petitioners without due process," and affirmed that prior rulings are binding.
On February 19, 2026, Goodwin alerted the U.S. Department of Justice that the court would no longer tolerate violations, a message confirmed as received by ICE. The ruling serves as "explicit notice to all officials—state and federal—involved in the detention of individuals whose cases come before this court." Continued detentions without individualized custody determinations will trigger consequences, including contempt proceedings and monetary sanctions for federal officials, and personal civil liability without qualified immunity for state jail officials. Goodwin concluded, "This court will enforce the Constitution."
These developments align with nationwide habeas corpus relief granted to detained immigrants challenging the administration's novel reading of the Immigration and Nationality Act over the past eight months.
