Culture

Annotating the Judge’s Decision in the Case of Liam Conejo Ramos, a 5-Year-Old Detained by ICE

Published

3 weeks ago

February 3, 2026

Annotating the Judge’s Decision in the Case of Liam Conejo Ramos, a 5-Year-Old Detained by ICE

One of the many unsettling images to emerge from the recent ICE surge in Minneapolis was that of 5-year-old Liam Conejo Ramos, in his blue bunny hat, standing in the January cold with the hand of a federal officer gripping his Spider-Man backpack.

Liam and his father, Adrian Conejo Arias, an asylum seeker from Ecuador, were taken from Minnesota to Texas and held at a detention facility outside San Antonio. Lawyers working on their behalf filed a petition for a writ of habeas corpus, an ancient judicial principle forbidding the government from holding anyone in custody without providing a legally tenable reason for doing so. On Saturday, Fred Biery, a federal judge in Texas’ Western District, granted their petition, freeing them.

That’s the boilerplate. But Judge Biery’s decision — which has gotten a lot of attention in legal circles and beyond — is much more than a dry specimen of judicial reasoning. It’s a passionate, erudite and at times mischievous piece of prose.

That may not have surprised some Texas court watchers. Judge Biery, who was appointed to the federal bench by President Bill Clinton in 1994, is known for his wit and writerly flair. His judicial order in a 2013 case involving San Antonio strip clubs is famous for its literary allusions (“to bare, or not to bare”) and its cheeky double entendres. A 2023 profile in San Antonio Lawyer magazine called him “a judge with a little extra to say.”

The extra in this case transforms what might have been a routine decision into a thorough scourging of the Trump administration’s approach to governance. This text isn’t much longer than one of Mr. Trump’s Truth Social posts. In fewer than 500 words, Judge Biery marshals literature, history, folk wisdom and Scripture to challenge the theory of executive power that has defined Trump’s second presidency.

It’s worth looking at how he does it.

OPINION AND ORDER OF THE COURT

Before the Court is the petition of asylum seeker Adrian Conejo Arias and his five-year-old son for protection of the Great Writ of habeas corpus. They seek nothing more than some modicum of due process and the rule of law. The government has responded.

He starts by juxtaposing the grandeur of habeas corpus with the modesty of the father and son’s claims, implying that what makes the writ “Great” is precisely its ability to protect the basic right of ordinary people not to be locked up arbitrarily. It does this by requiring that the government either provide reasons for holding them in custody or else let them go.

Judge Biery’s footnote directing readers to Blackstone’s commentaries and Magna Carta may be intended to give a remedial lesson to members of the administration. His larger point, though, is that to flout the guarantee of habeas corpus — as he insists the current deportation policy has done — is to threaten the integrity of the American constitutional order itself.

The case has its genesis in the ill-conceived and incompetently-implemented government pursuit of daily deportation quotas, apparently even if it requires traumatizing children. This Court and others regularly send undocumented people to prison and orders them deported but do so by proper legal procedures.

He calls attention to the grandiosity and sloppiness of the administration’s position while suggesting that its overreach reflects a more sinister intention.

Apparent also is the government’s ignorance of an American historical document called the Declaration of Independence. Thirty-three-year-old Thomas Jefferson enumerated grievances against a would-be authoritarian king over our nascent nation. Among others were:

1. “He has sent hither Swarms of Officers to harass our People.”

2. “He has excited domestic Insurrection among us.”

3. “For quartering large Bodies of Armed Troops among us.”

4. “He has kept among us, in Times of Peace, Standing Armies without the consent of our Legislatures.”

As the 250th birthday of American independence approaches, the president is being cast as King George III. The federal government’s indifference to habeas claims places it on the wrong side of the historical divide between individual liberty and unchecked state power, and thus at odds with the founding documents of the Republic.

“We the people” are hearing echos of that history.

And then there is that pesky inconvenience called the Fourth Amendment:

The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and persons or things to be seized.

U.S. CONST. amend. IV.

Civics lesson to the government: Administrative warrants issued by the executive branch to itself do not pass probable cause muster.

In constitutional terms, the judge finds that the administration has defied the Fourth Amendment and disregarded the separation of powers.

That is called the fox guarding the henhouse. The Constitution requires an independent judicial officer.

A barnyard metaphor puts the matter in plainer language: Because executive authority has the potential to be predatory, it needs to be checked by the judiciary branch. Judge Biery might also be sending a sly message to his colleagues on the U.S. Supreme Court, who have looked favorably on many of Mr. Trump’s expansive claims of executive branch power.

Accordingly, the Court finds that the Constitution of these United States trumps this administration’s detention of petitioner Adrian Conejo Arias and his minor son, L.C.R. The Great Writ and release from detention are GRANTED pursuant to the attached Judgment.

The language in which the judge renders his decision also sends a message, in this case to the president himself. Capitalization is a hallmark of Mr. Trump’s style, as it is of American legalese. The paragraph granting the petition bristles with uppercase nouns, which makes it all the more striking that the president’s name, otherwise absent from the ruling, is rendered in lowercase, as a card-table verb.

This may be a subtextual swipe at the president’s ego, but it’s consistent with the decision’s fundamental argument, which is that the president — any president — is ultimately smaller than the law.

Observing human behavior confirms that for some among us, the perfidious lust for unbridled power and the imposition of cruelty in its quest know no bounds and are bereft of human decency. And the rule of law be damned.

For Judge Biery, the case involves procedure, and morality too. When he allows himself to express his disapproval — to write judgmentally, rather than judicially — he is in effect arguing that these principles can’t be separated. Due process and human decency are two sides of the same coin.

Ultimately, Petitioners may, because of the arcane United States immigration system, return to their home country, involuntarily or by self-deportation. But that result should occur through a more orderly and humane policy than currently in place.

Philadelphia, September 17, 1787: “Well, Dr. Franklin, what do we have?” “A republic, if you can keep it.”

With a judicial finger in the constitutional dike,

It is so ORDERED.

Benjamin Franklin famously (and perhaps apocryphally) pointed out the fragility of orderly self-government, while the Dutch boy immortalized in the 19th-century novel “Hans Brinker, or the Silver Skates” did what he could to protect his neighbors from the fury of the unchecked sea.

That Judge Biery puts himself in their company suggests that he sees this decision less as a final judgment than as a warning.

SIGNED this 31st day of January, 2026.

FRED BIERY

UNITED STATES DISTRICT JUDGE

Credit&colon; Bystander

After his cautionary conclusion, the judge still has something extra to say, something that shifts the focus away from the rational, secular domain of jurisprudence.

Below his signature, he attaches the widely seen photograph of Liam. Underneath that — after an eloquently anonymous photo credit — are references to two verses from the New Testament. The judge doesn’t quote them, but they speak for him all the same.

Matthew 19:14

The Matthew verse — “But Jesus said, Suffer little children, and forbid them not, to come unto me: For of such is the kingdom of heaven” — is a well-known statement of compassion and care.

John 11:35

So, in its way, is John 11:35, the shortest verse in the English Bible. It is often quoted when things are so terrible that all other words fail:

“Jesus wept.”

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Culture

Try This Quiz on Thrilling Books That Became Popular Movies

Published

4 days ago

February 23, 2026

Press Room

Try This Quiz on Thrilling Books That Became Popular Movies

Welcome to Great Adaptations, the Book Review’s regular multiple-choice quiz about printed works that have gone on to find new life as movies, television shows, theatrical productions and more. This week’s challenge highlights thrillers first published as novels (or graphic novels) that were adapted into popular films. Just tap or click your answers to the five questions below. And scroll down after you finish the last question for links to the books and their screen versions.

Culture

Test Your Knowledge of the Authors and Events That Helped Shape the United States

Published

2 weeks ago

February 16, 2026

Press Room

Test Your Knowledge of the Authors and Events That Helped Shape the United States

Welcome to Lit Trivia, the Book Review’s regular quiz about books, authors and literary culture. In honor of Gen. George Washington’s birthday on Feb. 22, this week’s super-size challenge is focused on the literature and history related to the American Revolution. In the 10 multiple-choice questions below, tap or click on the answer you think is correct. After the last question, you’ll find links to exhibits, books and other materials related to this intense chapter in the country’s story, including an award-winning biography of the general and first U.S. president.

Culture

Video: How Much Do You Know About Romance Books?

Published

2 weeks ago

February 13, 2026

Press Room

Video: How Much Do You Know About Romance Books?

Let’s play romance roulette. No genre has dominated the books world in the last few years. Like romance, it accounts for the biggest percentage of book sales, their avid fan bases. Everyone has been talking about romance as a Book Review editor and as a fan of the genre myself, I put together a to z glossary of 101 terms that you should know if you want to understand the world of romance are cinnamon roll. You may think a cinnamon roll is a delicious breakfast treat, but in a romance novel, this refers to a typically male character who is so sweet and tender and precious that you just want to protect him and his beautiful heart from the world. Ooh, a rake. This is basically the Playboy of historical romance. He defies societal rules. He drinks, he gambles. He’s out on the town all night and is a very prolific lover with a bit of a reputation as a ladies’ man. FEI these are super strong, super sexy, super powerful, immortal, fairy like creatures. One of my favorite discoveries in terms that I learned was stern brunch daddy. A lot of daddy’s usually a male love interest who seems very intimidating and alpha, but then turns out to be a total softie who just wants to make his love interest brunch. I think there’s a misconception that because these books can follow these typical patterns, that they can be predictable and boring. But I think what makes a really great romance novel is the way that these writers use the tropes in interesting ways, or subvert them. If you can think of it, there’s probably a romance novel about it. Oops, there’s only one bed. This is one of my personal favorite tropes is a twist on forced proximity. Characters find themselves in very close quarters, where inevitably sparks start to fly. Why choose is the porkulus dose of the romance world. Sometimes the best way to resolve a love triangle is by turning it into a circle, where everyone is invited to play. Oops, we lost one spice level. There’s a really wide spectrum. You can range from really low heat or no spice, what might also be called kisses. Only then you start to get into what we call closed door or fade to Black. These books go right up to the moment of intimacy, and then you get into what we call open door, which is more explicit. And sometimes these can get very high heat or spicy and even start verging into kink. There’s one thing that almost every romance novel has in common. It’s that no matter what the characters get up to in the end, it ends with a happily ever after. I say almost every romance novel. Sometimes you’re just happy for now.