News & Insights

Background of the Case

Mr. Akhmedov, a native of Russia, entered the U.S. unlawfully in 2022. When he was detained in 2025, he asked the immigration judge (IJ) to release him on bond. The IJ agreed, setting a $15,000 bond, believing he was not a danger to the community or a flight risk.

The Department of Homeland Security (DHS) disagreed and appealed the decision to the BIA. DHS argued that Akhmedov had been inconsistent about where he actually lived—sometimes reporting a New York address, sometimes a Michigan address—and failed to timely notify the court of his moves.

The Key Problem: Address Inconsistencies

The Board focused on several red flags:

• Conflicting Addresses: At one point, Akhmedov claimed to live in Michigan with family, but he had also filed paperwork and received mail in New York.
• Late Updates: Immigration law requires that noncitizens update the court with any new address within 5 days of moving. Akhmedov waited more than a year to change his official address from New York to Michigan—only doing so after immigration officers confronted him in January 2025.
• Different Stories: He gave immigration officers one Michigan address but filed a different Michigan address in his court paperwork.

These inconsistencies raised doubts about whether he could be trusted to appear for future hearings.

What the Law Says About Bond

Under immigration law:

• A person seeking bond must prove they are not a danger to the community and not a flight risk.
• The judge has discretion, but the person carries the burden of showing they can be trusted to return to court.
• If the court believes there’s a risk they won’t appear, bond can be denied—even if the person has family in the U.S.

The BIA’s Decision

The Board overturned the IJ’s decision and ruled that Akhmedov should remain detained without bond.

• The BIA emphasized that address discrepancies and failure to report changes on time show a risk of flight.
• They noted Akhmedov had not lived in the U.S. very long, and the chances of him ultimately qualifying for relief from removal were uncertain.
• The Board concluded that no amount of bond money, not even $15,000, would guarantee his appearance in court.

Why This Case Matters

This case is now precedent, meaning it guides future bond decisions. It shows:

• Accuracy is critical: Noncitizens must keep the court updated with their correct address.
• Bond is not a right: Even if someone offers a large bond, it can be denied if the court doubts their reliability.
• Flight risk is taken seriously: Courts will not gamble on someone’s word if their records suggest they may disappear.

Bottom Line

In Matter of Akhmedov, the BIA made clear that trust and consistency are essential in immigration bond cases. Because Mr. Akhmedov failed to keep accurate records of where he lived and only updated his address after being confronted, the Board decided he could not be trusted to appear for his hearings. He will remain detained while his immigration case continues.