Vermont’s Attorneys Found the One Door ICE Can’t Close
The legal tool that worked in South Burlington has been working in courts across America — but how long it stays open may be up to the Supreme Court
When a federal immigration officer named Colton Riley began surveillance on a Dorset Street home in South Burlington on the morning of March 11, he was looking for a specific person: Deyvi Daniel Corona-Sanchez, a 24-year-old Mexican national previously deported in 2022. Riley had spotted a blue Toyota Camry in the driveway that registration records linked to Corona-Sanchez. From approximately 50 yards away, he believed the driver matched a prior immigration photograph of his target.
He was wrong.
When Riley attempted a vehicle stop, the driver fled. A chaotic pursuit followed through morning traffic near South Burlington High School, ending in multiple collisions. The car’s occupants fled on foot into the Dorset Street home, triggering an hours-long standoff. At 5:30 that evening, after obtaining a judicial warrant to search for Corona-Sanchez, federal agents breached the door. Three people were detained: Jisella Johana Patin Patin, her sister Daysi Camila Patin Patin, and Cristian Humberto Jerez Andrade. None of them were named in the warrant. Corona-Sanchez was not in the house.
Riley later filed a new court document stating he “no longer believes” Corona-Sanchez was even in the car. The driver, it turned out, was Jerez Andrade himself, who admitted as much in a two-and-a-half-hour interview with the FBI. A DHS press release issued five days after the raid had named Corona-Sanchez as the driver who “weaponized his vehicle and rammed our ICE law enforcement officers.” Riley’s subsequent court filing directly contradicted that account.
What happened next in Vermont’s federal courts is being held up as a model of legal accountability for ICE overreach. The reality is more instructive than that framing suggests.
The Tool
Vermont defense attorneys moved fast. Within days of the detentions, they had filed habeas corpus petitions in federal district court. The results followed quickly.
Habeas corpus — Latin for “you shall have the body” — is a writ protected by the Suspension Clause of Article I of the U.S. Constitution and implemented through federal statute, principally 28 U.S.C. § 2241. It requires the government to bring a detained person before a federal judge and justify, in open court, why it is holding them. If it cannot, the judge orders release. It applies to citizens and non-citizens alike, and it does not resolve a person’s underlying immigration case — proceedings in immigration court continue regardless of outcome. What habeas does is force the government to justify the detention itself, before an Article III federal judge not subject to removal by any administration.
That structural independence is what makes habeas corpus different from every other accountability mechanism states have attempted to deploy against federal immigration enforcement in 2026.
When federal officers fatally shot two U.S. citizens — Renée Good on January 7 and Alex Pretti on January 24, Good killed by an ICE agent and Pretti by Customs and Border Protection officers assigned to the same operation — during Operation Metro Surge in Minneapolis, Minnesota moved to investigate. It was blocked. The FBI told Minnesota’s Bureau of Criminal Apprehension it would no longer have access to case materials, scene evidence, or investigative interviews. Federal officials asserted exclusive control over their own agents’ conduct — precisely the authority Minnesota is now contesting in federal court, with uncertain outcome.
Vermont’s fight landed on entirely different terrain. The question was not whether a federal agent was justified in using force. It was whether detentions were lawfully authorized at all.
A warrant naming one person was used to enter a home and detain three people not named in it. That is precisely where habeas corpus operates, and where Article III judges have authority the executive branch cannot override. The administration can assert control over a use-of-force investigation and exclude state investigators from a crime scene. It cannot tell a federal judge to refuse a habeas petition.
That structural difference is what produced different outcomes in the two states.
Three Judges, Three Rulings
Three federal judges handled the Vermont cases, and their actions are worth distinguishing carefully.
U.S. District Judge Geoffrey Crawford ordered Jisella Johana Patin Patin released on habeas on March 16, finding that ICE had violated her constitutional rights by detaining her without any legitimate governmental purpose and calling her case “not really contestable.” Her attorney, Kristen Connors, argued she “would not be detained but for an unlawfully executed search warrant.” Crawford found the circumstances sufficiently extraordinary to order her immediate release rather than referring the matter to immigration court. In a subsequent written order, Crawford went further, finding that ICE violated Patin Patin’s constitutional due process rights and warning that prolonged detention without individualized justification can operate as part of a broader policy of mass detention.
For Cristian Humberto Jerez Andrade, U.S. District Judge William K. Sessions III ordered an expedited bond hearing in immigration court and warned that if Jerez Andrade remained detained, he would convene what he called a “major trial” on the constitutionality of ICE’s tactics in Vermont. The hearings also surfaced something beyond the warrant question itself. At the March 17 hearing, the government’s own attorney, Assistant U.S. Attorney Kaitlin Hazard, told the court she believed there may be active warrants for Jerez Andrade’s arrest — but admitted she could not say whether the warrants were active and had no knowledge of the underlying cases.
Sessions responded from the bench: “I don’t even know what he was convicted of, frankly. I don’t know if there’s an active arrest warrant.” The government was asking a federal judge to keep a man detained on a criminal record it had not verified. Jerez Andrade was ultimately released on a $10,000 bond by an immigration judge in Massachusetts. The “major trial” Sessions had threatened has not occurred.
U.S. District Judge Christina Reiss ordered the release of Daysy Camila Patin Patin on March 20, finding she posed no danger or flight risk and noting that her warrantless arrest may have raised Fourth Amendment concerns.
It is not accurate to say Vermont’s courts left the constitutional merits entirely unresolved. Crawford explicitly found a constitutional violation in Jisella Patin Patin’s case. What remains open is the broader question Sessions signaled he was prepared to address: a full judicial examination of the legality of the raid as a whole. That hearing has not happened.
Following a Wise Path
Vermont’s attorneys made a smart call. It was not a new one.
Since the Trump administration began its mass deportation push in early 2025, habeas corpus petitions have flooded federal courts from coast to coast. According to a ProPublica analysis using data from the Free Law Project, immigrants filed more habeas cases in the first thirteen months of the second Trump administration than in the previous three administrations combined — and the pace keeps rising. According to an El Paso Matters analysis of federal court records, the Western District of Texas alone received 759 such petitions in all of 2025 — a record for that district — with more than 1,300 filed in roughly the following three months. Across the country, legal aid organizations and courts have developed materials helping detained immigrants file petitions, and attorneys routinely race to file within hours of a client’s arrest specifically to lock in jurisdiction before ICE can transfer the detainee to a less favorable district. A Politico analysis found that more than 400 federal judges, appointed by presidents of both parties — including judges appointed by President Trump himself — have issued rulings against the administration’s no-bond detention policy.
What Vermont had on March 11 was a particularly clean constitutional fact pattern: a warrant for one person, executed against three others with no connection to it. That directness produced swift judicial results. In many other habeas cases nationally, the legal terrain is more contested and the outcomes less immediate.
What Didn’t Work
Vermont’s results are also incomplete in ways the coverage has underplayed.
On March 10 — the day before the Dorset Street raid — ICE agents conducted a traffic stop in Burlington and detained Jaime Eliceo Castro Guaman, 40, and a 24-year-old coworker. Castro Guaman’s attorney told the court that agents did not give him any reason for the stop until after they had taken him to their St. Albans field office, where they acknowledged they had been looking for someone else. Judge Sessions ordered Castro Guaman released on March 19, stating: “Other than a mistake by ICE, he would not have been detained. This is a person who was just living his daily life.”
But Castro Guaman’s coworker — the driver — was not brought before a Vermont federal judge. As of this writing he remains in ICE custody at the Northwest State Correctional Facility in St. Albans, according to the ICE Detainee Locator and Vermont Department of Corrections data. Officials have not released his name. He is the one person in Vermont’s March 11 story where the legal strategy has not produced a result, and he has received minimal coverage.
The Door May Not Stay Open
Vermont’s federal district sits within the Second Circuit, which covers Connecticut, New York, and Vermont. The Fifth and Eighth Circuits have moved in a different direction. On March 25 — six days before this story published — the Eighth Circuit Court of Appeals issued a 2-1 ruling in Avila v. Bondi upholding the Trump administration’s mandatory no-bond detention policy, joining a similar Fifth Circuit ruling from the previous month. Together, the two circuits now cover a broad stretch of the country from Minnesota to Texas to Louisiana.
The ruling turns on a statutory interpretation of the 1996 immigration reform law — specifically whether people arrested in the interior of the country, not just at the border, qualify as “applicants for admission” subject to mandatory detention without a bond hearing. Even the dissenting judge in the Eighth Circuit case, a Trump appointee, called the majority’s reading “novel” and one that “eluded the courts and five previous presidential administrations.”
Critically, even in states covered by the Fifth and Eighth Circuits, federal judges have continued granting habeas petitions on constitutional due process grounds that the statutory ruling does not foreclose. The Second Circuit, which covers Vermont, has not aligned with the Fifth and Eighth on the mandatory detention question. With circuits now divided, the issue will almost certainly reach the Supreme Court.
Vermont’s Next Step
Days after the raid, the Vermont House passed H.849, which would create a state-law cause of action allowing Vermonters to sue any government official — federal, state, or local — for violations of federal constitutional rights, while still permitting defendants to raise qualified immunity as a defense. The bill addresses the fact that the main federal civil rights statute, Section 1983, covers only state and local officials, and that existing remedies against federal agents are narrow and judge-made rather than statutory — a gap significantly widened by the Supreme Court’s gradual restriction of the Bivens doctrine over recent decades. The House passed H.849 97-39. As of March 31, 2026, it had been referred to the Senate Judiciary Committee and has not become law.
If enacted, H.849 would give Vermonters a remedy that does not depend on the speed of habeas filings or the receptiveness of a particular federal circuit. But it faces a threshold question: whether a state law creating civil liability for federal agents exercising federal authority survives a Supremacy Clause challenge. The bill’s sponsor acknowledged that risk on the floor and argued Vermont would have strong counterarguments. Gov. Phil Scott, who publicly condemned the March 11 operation as “totally unnecessary,” has indicated general support for the bill’s goals but has not committed to signing it.
The Bigger Picture
Officer Riley’s identification error on Dorset Street — a blue Camry, a prior immigration photograph, 50 yards of distance — set in motion a chain of events that put Vermont at the center of a national legal question most Vermonters had never considered. The question is not whether Vermont’s attorneys were skillful, or whether its federal judges were willing to use their authority. They were both. The question is what tool they used, and whether it will remain available.
Habeas corpus before an Article III judge is one of the few mechanisms in the current legal environment that the executive branch has not been able to unilaterally shut down. The Suspension Clause bars even Congress from eliminating the writ except in cases of rebellion or invasion. That durability is what made it effective in South Burlington, and what has made it effective in tens of thousands of cases from El Paso to Burlington over the past year.
Vermont’s attorneys found the door and moved through it quickly. So have lawyers in Texas, California, Minnesota, and dozens of other states — more than 30,000 times and counting. The difference in Vermont was a fact pattern so clean that three federal judges found it, in the words of one of them, not really contestable.
The broader constitutional questions those facts raised — about the limits of federal enforcement power, about what ICE can do when it has detained the wrong people — have not been fully answered. Judge Sessions said he was prepared to answer them. That trial has not happened yet.
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