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Original Date Announced
January 21, 2026ICE Acting Director Todd Lyons issued a memorandum to All ICE Personnel, "Utilizing Form I-205, Warrant of Removal," authorizing all ICE special agents and deportation officers to execute Forms I-210 (administrative warrants) without anything more to arrest noncitizens subject to final orders of removal in their residences. The memo refers to a recent determination by the DHS Office of the General Counsel that nothing in the U.S. Constitution, the INA, or immigration regulations prohibits relying on administrative warrants for this purpose. The memo specifically authorizes ICE personnel to use force to enter a residence after knocking and announcing their presence and providing a reasonable opportunity to open the door.
ICE basic training provides that "a warrant of removal/deportation does NOT alone authorize a 4th amendment search of any kind."
The memorandum was produced as part of a whistleblower complaint to Congress.
Trump 2.0 [ID# 2175]
2025.05.12 Utilizing Form I-205 Warrant of Removal - ICEEffective Date
May 12, 2025Current Status
NoneOriginal Trump Policy Status
Status: Final/ActualTrump Administration Actions: Agency Directive Change in PracticeSubject Matter: InteriorAgencies Affected: ICEAssociated or Derivative Policies
- January 20, 2025 EO 14159: "Protecting the American People Against Invasion"
- December 4, 2025 DHS launches Operation Metro Surge in Minnesota
Pre Trump-Era Policies
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June 14, 2007
Letter from Sec. Chertoff to Sen. Dodd explaining that "A warrant of removal is administrative in nature and does not grant the same authority to enter dwellings as a judicially approved search or arrest warrant."
2007.06.14 Secretary Chertoff letter re Administrative Warrants -
July 26, 2021
ICE basic training provides that "a warrant of removal/deportation does NOT alone authorize a 4th amendment search of any kind."
2021.07.26 ICE ERO 4th Amendment Training
Documents
Trump-Era Policy Documents
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New Policy
Original Source:
2025.05.12 Utilizing Form I205 Warrant of Removal - ICE
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Prior Policy
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Prior Policy
Original Source:
2021.07.26 ICE ERO 4th Amendment Training
To provide information, corrections, or feedback, please email IPTP.feedback@gmail.com
Commentary
2026.01.21 Immigration officers assert sweeping power to enter homes without a judge’s warrant, memo says - AP
Associated Press reports on a whistleblower complaint to Congress that reveals the ICE memo described in this entry as well as ICE's 2021 basic training guidance regarding 4th Amendment prohibitions against searches conducted pursuant to an administrative warrant.
The memorandum provides context to recent reports, including one in which '[f]ederal agents this month rammed the door of the Minneapolis home of a Liberian man with a deportation order from 2023, who was then arrested. Documents reviewed by The AP revealed that the agents only had an administrative warrant — meaning there was no judge who authorized the raid on private property."
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