Mario Cesar Martinez Castrillon, a citizen of Peru who had been paroled into the United States under the Migrant Protection Protocols program, was detained during a scheduled ICE check-in appointment on January 13, 2026. He had been living in Memphis, Tennessee, had obtained a driver's license and work authorization, and had been regularly reporting to ICE as required. The court denied his habeas corpus petition challenging his detention without an individualized bond hearing. Jose Roberto Casanova-Vidal, a citizen of Peru who entered the U.S. in November 2022, was detained on December 1, 2025 after voluntarily appearing at the Memphis Immigration office for allegedly failing to comply with ATD program conditions. He had previously been released on parole due to time in custody constraints and placed in the Alternatives to Detention program. The court denied his habeas petition seeking release or a bond hearing, ruling that as an applicant for admission he is subject to mandatory detention under federal law.