Echavarria v. Pitts

DeMOSS, Circuit Judge:

This appeal asks us to consider whether, in order to satisfy due process, the government must take additional reasonable steps to notify a bond obligor that the bond has been breached when the government has knowledge that the initial attempt at notice failed. We hold that in such circumstances additional reasonable steps must be taken.

I

When an alien has been detained by the Department of Homeland Security (DHS), an obligor may post a $1,500 cash bond to secure the alien’s release. The obligor signs an agreement with DHS, agreeing to be responsible for informing DHS of…