The Tenth Circuit Court of Appeals rejected a Trump administration policy on Tuesday, June 30, that mandated the detention of Rigoberto Santillan-Quiroz, a longtime U.S. resident, without bond. This is a high-stakes appellate ruling that directly affects immigration detention practice and bond-hearing strategy across six western states. The court ordered a bond hearing for Santillan-Quiroz and found that individuals now are entitled to have the bond hearings that should result in release for many after months of being wrongfully held by ICE.
What changed
In July 2025, the Trump administration issued new guidance that denies bond to people in detention while their immigration cases proceed — a categorical policy known colloquially as “no bond.” The Tenth Circuit rejected this policy on June 30, 2026, in the case of Rigoberto Santillan-Quiroz.
Santillan-Quiroz, with the American Civil Liberties Union’s Immigrants’ Rights Project, ACLU of Oklahoma, ACLU of Colorado, and immigration attorney Kelli Stump appealed the district court’s decision in January 2026. The court ordered a bond hearing for Santillan-Quiroz, who, after eight months of detention, will finally have an opportunity to demonstrate that there is no justification for his continued detention.
The ruling is now binding precedent in the Tenth Circuit, which covers Colorado, Oklahoma, Kansas, New Mexico, Utah, and Wyoming.
Why it matters
This ruling directly reverses how immigration judges and immigration prosecutors must handle bond determinations in the Tenth Circuit. You can no longer rely on the categorical detention policy to hold clients without a hearing. This is a huge victory for thousands of people currently being held without access to bond in immigration detention centers across Colorado, Oklahoma, Kansas, New Mexico, Utah, and Wyoming; these individuals are now entitled to have the bond hearings that should result in release for many after months of being wrongfully held by ICE.
The practical impact is significant: clients detained under the Trump administration’s mandatory detention policy now have a right to an individualized bond hearing before an immigration judge. This aligns with decades of prior practice (before July 2025) where clients could seek bond regardless of their entry status.
Immigration practitioners representing detainees in the Tenth Circuit should immediately file or re-file bond motions and habeas petitions where clients were denied hearings under the categorical detention policy.
Way forward
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File or re-file bond motions for any client currently detained in the Tenth Circuit who was denied a hearing under the mandatory detention policy. The ruling creates a pathway to immediate relief.
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Prepare individualized mitigation for bond hearings: flight risk, ties to community, employment, family, and criminal history. Immigration judges must now engage in fact-specific analysis rather than applying a blanket rule.
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Monitor appellate status in other circuits. The Tenth Circuit’s ruling joins three appeals courts and decisions from over 450 district court judges across the country; judges have mandated that the Trump administration release many of these immigrants from detention, routinely finding that their categorical detention without a bond hearing is unlawful. Conflicting appellate rulings may trigger Supreme Court review.
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Document and preserve the record of any prior detention under the no-bond policy. Clients may have standing to seek refunds of bond paid and removal of monitoring conditions imposed while wrongfully detained.
Disclaimer
This article is for informational purposes only and is not legal advice. Fola is a software company, not a law firm. Immigration law is complex and changes frequently without notice. You should consult a licensed immigration attorney about your specific situation and verify all information against the primary source linked above. The Tenth Circuit’s ruling is binding only within its jurisdiction; practitioners in other circuits should consult local appellate decisions and habeas practice in their district courts.