Castaneda v. Souza, ___ F.3d ___, ___ (1st Cir. Oct. 30, 2014) (Because INA 236(c), 8 U.S.C. 1226(c) only applies to aliens detained when . . . released from criminal custody, and because the petitioners were not timely detained under any reasonable interpretation of the statute [they were each arrested by ICE over four years after release], we conclude that the petitioners are not subject to mandatory detention under 1226(c) and are entitled to an individualized bail hearing under 1226(a). We therefore affirm the district courts grant of habeas corpus relief in each case.); see Casas-Castrillon v. Dept. of Homeland Sec., 535 F.3d 942, 950 (9th Cir. 2008); Ly v. Hansen, 351 F.3d 263, 272 (6th Cir. 2003); Sylvain,714 F.3d at 157 (collecting cases); Alikhani v. Fasano, 70 F. Supp. 2d 1124, 1130 (S.D. Cal. 1999); Ortiz v. Holder, No. 2:11-cv-1146 DAK, 2012 WL 893154, at *3-4 (D. Utah Mar. 14 2012); Harris v. Lucero, Civil Action No. 1:11-cv-692, 2012 WL 603949, at *3 (E.D. Va. Feb 23, 2012); Parfait v. Holder, Civil No. 11-4877 (DMC), 2011 WL 4829391, at *4-9 (D.N.J. Oct. 11, 2011); Rianto v. Holder, No. CV-11-0137-PHX-FJM, 2011 WL 3489613, at *3 (D. Ariz. Aug. 9, 2011).