Immigration officers have been empowered to enter people’s homes by force, according to an internal Immigration and Customs Enforcement memo.
The memo, obtained by the Associated Press and dated May 12, 2025, says that ICE officers in possession of administrative warrants—that is, Form I-205s and not judicial warrants signed by a judge—must first “knock and announce,” stating their identity and purpose, before allowing residents a “reasonable chance” to answer the door.
“Should the alien refuse admittance,” the memo continues, “ICE officers and agents should use only a necessary and reasonable amount of force to enter the alien’s residence, following proper notification of the officer’s or agent’s authority and intent to enter.”
The memo was sent by Acting Director Todd Lyons.
The memo itself acknowledges that the Department of Homeland Security “has not historically relied on administrative warrants alone” to make arrests, but that the DHS Office of General Counsel had recently determined that the law does not prohibit relying on administrative warrants. It does not provide further detail as to how that determination was made. The Fourth Amendment, which governs the actions of law enforcement agencies, protects people against unreasonable search and seizure.
As a result, the convention had previously been that only an arrest warrant signed by a judge would allow agents to forcibly enter someone’s home. Advocates and immigrant-friendly politicians, including New York Mayor Zohran Mamdani, have routinely assured immigrants that ICE agents cannot enter someone’s home without a judicial warrant signed by a judge.
“If ICE does not have a judicial warrant signed by a judge,” Mamdani said in a video shared to social media in December, “you have the right to say, ‘I do not consent to entry,’ and a right to keep your door closed.”
The two government employees responsible for leaking the memo to non-profit organization Whistleblower Aid also revealed that instructors training new ICE recruits are required to teach them that Form I-205 allows agents to arrest people in their homes despite official department training materials explicitly stating that “a warrant of removal/deportation does not alone authorize a 4th amendment search of any kind.”
When contacted by the Daily Beast for comment, DHS Assistant Secretary Tricia McLaughlin said, “Every illegal alien who DHS serves administrative warrants/I-205s have had full due process and a final order of removal from an immigration judge. The officers issuing these administrative warrants also have found probable cause. For decades, the Supreme Court and Congress have recognized the propriety of administrative warrants in cases of immigration enforcement.”
McLaughlin did not respond to questions about whether ICE officers have been entering people’s homes while relying solely on administrative warrants since the memo was issued.
Last week, Associated Press reporters witnessed ICE officers ramming through the front door of the Minneapolis home of a Liberian man, armed with a deportation order from 2023, heavy tactical gear, and rifles. A review by the Associated Press found that agents only had an administrative warrant.
On Sunday, a grandfather who lives in Minnesota was forcibly removed from his home by ICE agents, despite having been a U.S. citizen since 1991.
“I was praying. I was like, ‘God, please help me, I didn’t do anything wrong.’ Why do they do this to me? Without my clothes on,” ChongLy “Scott” Thao told Reuters on Monday as his friends fixed his broken front door.
Minnesota has been the most high-profile target of ICE operations this year, resulting in the shooting death of 37-year-old mom-of-three Renee Nicole Good at the hands of ICE officer Jonathan Ross and the non-fatal shooting of a Venezuelan immigrant during a traffic stop.
