Immigration detention in the second Trump administration

For broader coverage of this topic, see Immigration policy of the second Trump administration.

Average daily population of detained immigrants held by the United States government for the fiscal years 1994-2025

The second Trump administration has expanded immigration detention in the United States as part of the administration's mass deportation policy. On January 23, 2025, ICE began to carry out raids on sanctuary cities, with hundreds of immigrants detained and deported. The Trump administration reversed the policy of the previous administration and gave ICE permission to raid schools, hospitals and places of worship. ^{[1] [2]} Fears of ICE raids have negatively impacted the agriculture, ^[1] construction, ^[3] tourism, ^[4] and hospitality industries. ^[5] ICE agents conducting raids frequently travel in unmarked vehicles, wear plainclothes and facial coverings, and refuse to identify themselves or present warrants. ^{[6] [7] [8] [9]} The administration ordered the re-opening of the Guantanamo Bay detention camp to hold potentially tens of thousands of illegal immigrants, ^{[10] [11]} but has faced logistical and legal difficulties using it as an immigrant camp. ^[12] The majority of detentions have been for non-violent matters. ^{[13] [14] [15]} Courts have ruled more than 4,400 times that the Trump administration is detaining people illegally. ^[16] Several US citizens have been detained and deported. ^[17] Thousands of people detained by ICE have disappeared from ICE records and their whereabouts are unknown. ^[18]

Immigration raids

Main article: List of immigration raids and arrests in the second Trump presidency

Immigration raids were widely described by both critics and promoted by the Trump administration as purposefully aggressive, with Trump saying they "haven't gone far enough". Videos of ICE and CBP agents smashing car windows, tackling mothers, and lobbing tear gas at citizens and peaceful protesters were quickly shared on social media leading to immense criticism and numerous lawsuits. ^{[19] [20] [21]} Extensive criticism ensued following a "military-style" ICE raid at a residential apartment complex in Chicago's South Shore as part of Operation Midway Blitz in the early morning hours of September 30, 2025. The operation featured agents rappelling from black hawk helicopters at 1am, tossing flashbangs at families, and rounding up and zip-tying adults, children, and U.S. citizens. ^[22]

As early as January 23, high-profile ICE raids occurred in Atlanta, Boston, Denver, Miami, New York City, Newark, Philadelphia, Seattle, and Washington, D.C., detaining 538 people. The mayor of Newark claimed that ICE raided a local establishment and detained illegal immigrants as well as citizens, including a veteran, without a warrant. ^{[23] [24] [25]} On April 24, immigration agents raided a family's home in Oklahoma City and seized the residents' belongings including laptops, phones and cash, despite them being US citizens who were not the targets of the warrant issued for the home. Assistant DHS secretary Trisha McLaughlin defended the raid, saying it was "ultimately a successful operation". ^[26]

On September 4, an immigration raid occurred at a Hyundai plant in Georgia detaining approximately 475 workers in what was described as the largest immigration enforcement operation carried out at a single location by Homeland Security. ^[27] The raid led to a diplomatic row between the United States and South Korea, and analysts described it as deterring foreign investment in America. ^{[28] [29]}

Administrative warrants

Most immigration arrests are carried out under non-judicial administrative warrants that do not authorize use of force for nonconsensual entry onto private property or other nonpublic spaces, and are authorized by immigration judges, immigration officers, or agencies within the executive branch rather than a federal district judge or magistrate judge. ^{[30] [31]} In January 2026, Whistleblower Aid filed an anonymous complaint with Congress disclosing an internal May 2025 ICE memorandum articulating a policy directive approved by acting ICE Director Todd Lyons that authorized the use of administrative warrants for arrest by ICE agents in places of residence that the complaint contends violates the Fourth Amendment. ^[32] While the memo states that DHS did not rely exclusively on administrative warrants for alien arrests in places of residence historically, the memo also states that the DHS general counsel's office had recently concluded that doing so was not prohibited by the U.S. Constitution, the Immigration and Nationality Act, or immigration regulations. ^[33] While the memo asserts that administrative warrants are not search warrants and have a knock-and-announce requirement, the memo also asserts that ICE agents are permitted to forcibly enter residences to make arrests and detentions pursuant to a final order of removal issued by an immigration judge, the Board of Immigration Appeals, a federal district judge, or a federal magistrate judge. ^[34]

The complaint alleges that the memo was not widely circulated within the agency and exposure to it was highly controlled, with some DHS employees being asked to return the memo after reading it; one of the two whistleblowers was only allowed to view the memo alongside a supervisor, required to return it after reading, and barred from taking any notes. ^[32] However, the complaint alleges that the memo's content has been used to train ICE officers deployed on the nationwide immigration raids and continues to be required guidance for new ICE officers and trainees—despite other written DHS training materials explicitly contradicting the memo's administrative warrants guidance. ^[32] How widely the memo's guidance was applied was unknown at the time of the complaint; the Associated Press reported that documents it reviewed of a forced entry and arrest in Minneapolis on January 11, 2026 showed the ICE agents involved only procured an administrative warrant. ^[32] In a press statement addressing the memo after its disclosure, DHS spokesperson Tricia McLaughlin stated that persons affected by administrative warrants received "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." ^[33]

The memo has been criticized by legal scholars and immigration lawyers, ^{[35] [36]} and at least one lawsuit has been filed to block its implementation. ^{[37] [38]} Administrative warrants are authorized and generally required for immigration arrests under Section 1226(a) of Title 8 of the United States Code, ^{[39] [40]} while Section 1357(a) of Title 8 provides a plain view of illegal entry exception and a reason to believe and likelihood of escape exception to Section 1226 that allow for warrantless arrests. ^{[41] [42]} Lyons issued a subsequent memo pursuant to Section 1357(a) in January 2026, ^{[43] [44]} while a federal judge in Oregon ruled in a class-action lawsuit against DHS the following month that immigration officers may not conduct warrantless arrests without a likelihood of escape. ^[45] While the U.S. Supreme Court upheld the use of administrative warrants in Abel v. United States (1960) and the constitutionality of Section 1226 in Demore v. Kim (2003), ^[39] the Congressional Research Service (CRS) referenced the Court's decisions in Almeida-Sanchez v. United States (1973) and United States v. Brignoni-Ponce (1975) in reports released in 2021 and 2025 as establishing that the Fourth Amendment's prohibition against "unreasonable searches and seizures" extends to arrests and detentions to enforce civil immigration law in the interior of the United States—where the border search exception does not generally apply and without regard to an alien's immigration status. ^{[46] [41]}

Referencing the Supreme Court's decision in Maryland v. Pringle (2003), the 2025 CRS report noted further that lower federal courts have interpreted the reason to believe exception of Section 1357(a) for warrantless immigration arrests to be equivalent to the Fourth Amendment's probable cause requirement, and have applied the Supreme Court's holding in Graham v. Connor (1989) that the Fourth Amendment prohibits the use of excessive force in criminal law cases over immigration arrests. ^[47] While noting the Supreme Court's holdings in California v. Greenwood (1988) and Florida v. White (1999) permitting warrantless searches in public spaces due to the absence of a reasonable expectation of privacy, the 2025 CRS report references lower federal court rulings that nonetheless held that ICE agents must have probable cause of the presence of an unlawful alien and the exigent circumstance of a likely escape to conduct a warrantless arrest, as well as conflicting lower court rulings on conducting warrantless surveillance for immigration enforcement in places of worship due to restrictions from the First Amendment and the Religious Freedom Restoration Act. ^[48]

Noting the Supreme Court's rulings in Stoner v. California (1964), Mancusi v. DeForte (1968), Schneckloth v. Bustamonte (1973), Marshall v. Barlow's (1977), Payton v. New York (1980), California v. Ciraolo (1986), and Riley v. California (2014), the 2025 CRS report cites lower federal court rulings that have held that administrative warrants do not confer the same legal authority as judicial warrants, and have ruled that ICE agents have violated the Fourth Amendment when forcibly entering private homes without a judicial warrant and where no established Fourth Amendment exceptions applied. ^[48] However, referencing the Supreme Court's rulings in Brignoni-Ponce, Florida v. Royer (1983), Immigration and Naturalization Service v. Delgado (1984), and Muehler v. Mena (2005), the 2025 CRS report noted that while the Court has held that while interrogation alone without detention about a person's citizenship in public places does not violate the Fourth Amendment, the Court has held that brief detentions without arrest, traffic stops, and stop-and-frisks require at least reasonable suspicion based on the totality of the circumstances to be conducted without a warrant (including in proximity to the borders of the United States). ^[49] Following these precedents, the CRS notes that lower federal courts have ruled that the reasonable suspicion standard does not authorize brief detentions by immigration officers strictly due to suspected alienage (but instead requires suspected unlawful presence), nor detaining workers during interrogation. ^[50]

Facial recognition technology

In a lawsuit filed in January 2026, Illinois and Chicago alleged that DHS agents had used Mobile Fortify more than 100,000 times in the interior of the United States. ^[51] First brought to public attention in reporting by 404 Media in June 2025, ^[52] the mobile app features a facial recognition system on photos taken to search federal and state databases that a federal court has ruled are impermissible for procuring administrative warrants due to inaccuracy, while the Illinois and Chicago lawsuit alleges that the department's use of the app exceeds what federal law authorizes for data collection of biometrics. ^[53] While the lawsuit alleges specific cases of federal immigration agents scanning a person's face without consent, news organizations have reported that federal immigration agents frequently perform such scans without consent and legal commentators have noted that the use of such facial recognition technology (FRT) by federal immigration enforcement had been previously limited to ports of entry and in investigations. ^{[53] [51]}

In the same month the Illinois and Chicago lawsuit was filed, The New York Times reported that unnamed current and former DHS officials have confirmed that Mobile Fortify, the FRT and location tracking tools developed by Palantir Technologies and Clearview AI, and other cellphone hacking and social media tracking tools are being used by DHS immigration enforcement agencies to both attempt to identify undocumented immigrants and to track the locations and monitor the online activity of citizens who are anti-deportation protestors. ^{[54] [55]} U.S. Senator Ed Markey with colleagues wrote letters to ICE in September 2025 and November 2025 requesting that the agency stop using the technologies and answer questions about the agency's use of them (specifically if they were being used to identify citizens, protestors, and minors), ^[56] while a bill proposed in Congress in January 2026 would ban DHS from using Mobile Fortify and similar apps. ^[53] Mobile Fortify was developed by NEC, a Japanese information technology company. ^[51]

In 2020, the Government Accountability Office (GAO) issued a report that noted that while there is no comprehensive federal data privacy law or federal law that specifically and explicitly regulates commercial use of FRT, the GAO suggested that federal laws that address the commercial use, collection, and storage of personal data may nonetheless apply to commercial FRT and other biometrics technology—specifically, the Driver's Privacy Protection Act, the Health Insurance Portability and Accountability Act, the Fair Credit Reporting Act, the Family Educational Rights and Privacy Act, the Computer Fraud and Abuse Act, the Children's Online Privacy Protection Act, and Section 5 of the Federal Trade Commission Act. ^{[57] [58]} Along with the Congressional Research Service in a 2020 report, ^[59] the GAO similarly suggested in a 2022 report that the requirements for federal agency collection, use, and storage of personal data under the Privacy Act of 1974 and the E-Government Act of 2002 may also apply to FRT and biometrics technology. ^[60] The 2020 GAO and CRS reports both note that there are state laws that explicitly regulate commercial use of biometric data or FRT (referencing the California Consumer Privacy Act), ^{[61] [62]} while a 2023 CRS report notes that DHS is required to maintain a biometric entry-and-exit records system on non-citizens under the Patriot Act. ^{[63] [64]}

The 2020 CRS report noted that federal case law analyzing constitutional issues with FRT is limited. ^[65] While noting the Supreme Court's decision in Katz v. United States (1967) that established the reasonable expectation of privacy standard and legal test for what constitutes search and seizures generally permits warrantless searches in public places, the CRS also noted that the Court qualified its ruling in United States v. Knotts (1983) upholding the warrantless surveillance at issue in the case because, despite the fact that the evidence obtained by the government could have been acquired by visual surveillance in public, "different constitutional principles may be applicable" if "twenty-four hours surveillance of any citizen of this country [were] possible." ^[66] As such, the CRS noted that the Court applied the qualification to its holding in Knotts to its decisions in United States v. Jones (2012) and Carpenter v. United States (2018) requiring warrants for searches that used GPS tracking and cellphone surveillance—which led the CRS to conclude that the Court's decisions in the cases suggest that when surveillance conducted in public is prolonged and continuous may nonetheless constitute a search requiring a warrant under the Fourth Amendment. ^[67]

However, the CRS also noted in its 2020 report that while the Court declined to extend the third-party doctrine established in United States v. Miller (1976) and Smith v. Maryland (1979) to the surveillance presented in Carpenter, the CRS suggested, citing a lower court ruling, that law enforcement use of FRT on driver's license photographs maintained by a department of motor vehicles or photographs held by other third parties probably does not implicate the Fourth Amendment. ^[68] Nonetheless, citing news reporting about mass surveillance in China, limitations on the technological infrastructure for law enforcement's use of FRT in the United States, and lower federal court rulings that did not address what degree of prolonged surveillance in public implicates the Fourth Amendment, the CRS concluded that how the Court's Fourth Amendment jurisprudence would apply to use of FRT and other biometric technology in the interior of the United States was unclear and unresolved. ^[69]

Provided that the searches are routine and minimally intrusive, the 2020 CRS report noted that lower federal courts had held that use of FRT and collection of biometric data at the borders of the United States, ports of entry, or their functional equivalent are allowed under the border search exception to the Fourth Amendment. ^[70] While the CRS noted that little federal case law addresses challenges to wrongful arrests based on unreliable FRT, the CRS referenced the Supreme Court's decisions in Aguilar v. Texas (1964), Illinois v. Gates (1983), Maryland v. Pringle (2003), and Florida v. Harris (2013) and other lower federal court rulings on the reliability of informants and detection dogs in suggesting that the reliability and accuracy of specific FRT systems would likely be subject to review by courts when assessing the legal basis for a search or an arrest and following the totality of the circumstances standard established in Illinois v. Gates. ^[71]

The 2020 CRS report noted that the Supreme Court and lower federal courts had not addressed challenges to FRT use under the First Amendment, but referencing the Court's holding NAACP v. Alabama (1958) establishing a relationship between freedom of association and privacy, the CRS suggested that there could be First Amendment implications for use of FRT if it is used to conduct retaliatory arrests and prosecutions for persons engaged in protected speech. ^[72] The 2020 CRS report also noted that federal courts had rarely addressed equal protection challenges to use of FRT under the Due Process Clause of the Fifth Amendment or the Equal Protection Clause of the Fourteenth Amendment, and referencing Washington v. Davis (1976), Village of Arlington Heights v. Metropolitan Housing Development Corp. (1977), Personnel Administrator of Massachusetts v. Feeney (1979), and McCleskey v. Kemp (1987), the CRS noted that such claims would require plaintiffs to show that the actions of defendants have both a discriminatory effect and purpose for the claims to be upheld. ^[73]

Sanctuary jurisdictions

In 2025, San Francisco and other local governments with sanctuary city policies filed a lawsuit against the administration over Executive Order 14159, Executive Order 14218, and a February 2025 memo issued by Attorney General Pam Bondi over imposed conditions to receive federal funding that the plaintiffs alleged were not authorized by Congress and that effectively required enforcement of federal immigration law, while similar lawsuits were filed in Massachusetts and Rhode Island. ^[74] Conversely, the second Trump administration filed litigation against Illinois, New York, Colorado, New York City, Boston, Rochester, New York, and multiple cities in New Jersey for their sanctuary policies. ^[75] In a January 24, 2026 letter to Minnesota Governor Tim Walz following the protests in the state in response to the killings of Renée Good and Alex Pretti during the mass deployment of ICE and Border Patrol to the state, Bondi requested that the state government repeal sanctuary policies in the state, give the Justice Department's Civil Rights Division access to the state's voter rolls, and share its Medicaid, Food and Nutrition Service, and Supplemental Nutrition Assistance Program records with the Justice Department for its investigation of the 2020s Minnesota fraud scandals. ^{[76] [77]}

A day after the letter was sent, Trump called on Congress to pass legislation to ban state and local government sanctuary policies and called on Walz, Minneapolis Mayor Jacob Frey, and all Democratic governors and mayors "to formally cooperate with the Trump Administration to enforce our Nation's Laws, rather than resist and stoke the flames of Division, Chaos, and Violence." ^[78] Bondi's letter was referenced in oral arguments for a class-action lawsuit filed by Minnesota against DHS to block the mass operation in the state. ^{[79] [80]} In separate reports issued in 2025, the CRS noted that the Supreme Court held in Hines v. Davidowitz (1941), Kleindienst v. Mandel (1972), and Arizona v. United States (2012) that immigration laws passed by Congress generally preempt state laws under the Supremacy Clause of Article Six, ^{[81] [82]} and along with other lower federal court rulings, the CRS has noted that state and local law enforcement have limited legal authority to arrest and detain aliens for immigration law violations, and generally may only do so under a cooperative agreement with DHS under Section 1357(g) of Title 8 of the United States Code. ^{[83] [84]}

However, the CRS also noted that the Court held in De Canas v. Bica (1976), Chamber of Commerce v. Whiting (2011), and Kansas v. Garcia (2020) that not all state laws related to aliens are immigration regulations preempted by federal law. ^{[85] [82]} Moreover, referencing the Court's decisions in New York v. United States (1992) and Murphy v. National Collegiate Athletic Association (2018), the CRS has noted that lower federal courts have held that the Tenth Amendment prohibits the federal government from commandeering state government resources to enforce federal immigration law, and that state and local governments enforcing a federal detention request can be held in violation of the Fourth Amendment if the request lacks probable cause—which is why various state and local governments have enacted laws limiting their law enforcement agencies from cooperating with federal immigration enforcement in order to shield themselves from legal liability. ^{[86] [82]} The Supreme Court incorporated the Fourth Amendment's requirements for warrants directly against state governments in Aguilar v. Texas (1964) by the Due Process Clause of the Fourteenth Amendment. ^[87]

Also, referencing South Dakota v. Dole (1987) and National Federation of Independent Business v. Sebelius (2012), the CRS has also noted that the Taxing and Spending Clause of Article One, Section Eight does not authorize Congress to place conditions on federal funding to state governments without providing notice to recipients identifying what constitutes compliance and noncompliance with the conditions to receive the funding, that are unrelated to the essential purpose of the funding, that are coercive such that they compel actions that the states would otherwise not perform, and where the conditions would require states to act unconstitutionally. ^[88] As such, the CRS noted in a separate report issued in 2021 that lower federal courts struck down Executive Order 13768 issued during the first Trump administration because it ordered the Justice Department and DHS to restrict the grant eligibility of sanctuary jurisdictions for noncompliance with Section 1373 of Title 8, ^[89] and Congress had not required compliance with Section 1373 for the specific funding that the first Trump administration ordered to be withheld. ^{[90] [86] [88]}

Detention rate

United States Secretary of Homeland Security Kristi Noem speaking to law enforcement agents during an ICE raid, 2025

Trump set a goal of 1,200 to 1,500 ICE arrests per day, but his administration has largely failed to meet these targets. Trump's administration saw about 800 ICE arrests per day after he took office in January, declining to fewer than 600 arrests per day in February, at which point ICE stopped publishing daily statistics. Trump's rates of arrests lag those of both the Obama and Biden administrations, despite ICE officers working extra shifts and being given arrest quotas. Trump's relatively low rate of immigration enforcement has been attributed to limitations in ICE resources and staffing, as well as a dramatic decrease in the number of immigrants illegally crossing the US-Mexico border since Trump took office. ^{[91] [92] [93] [94]} In May 2025, Kristi Noem and Stephen Miller pushed ICE to increase its arrest numbers to 3,000 per day. ^[95] ICE encouraged officers to make warrantless arrests and to "turn the creative knob up to 11" in meeting the updated detention targets, including interviewing and arresting individuals they may coincidentally encounter dubbed "collaterals". ^[96]

ICE officials said in early March 2025 that 32,809 arrests were made between January 20 and March 10, 2025. They also accused the Biden administration of inflating arrest statistics. ^[97] At the beginning of 2025, there were over 41,000 people in ICE custody. ^[98] By mid-March, ICE reported holding 46,269 people in custody. ^[99]

In early September 2025, the Board of Immigration Appeals reversed an earlier decision that had allowed immigration judges to conduct bail hearings for detained migrants who entered the US without inspection. ^[100] Immigration attorneys and advocates called this decision "deeply flawed" ^[101] and "a terrible plan" that would enrich private prison companies holding detainees in substandard conditions. ^[102] Later that month, a habeas corpus petition was filed on behalf of a detained 46-year-old double amputee with a pending permanent residence petition who had been taken into ICE custody based on a burglary conviction from his teenage years for which he had been pardoned in 2010. His attorney predicted that thousands more such petitions would be filed in the wake of the immigration appeals board decision. ^[103]

By February 2026, The New York Times reported "federal judges have found that the Trump administration has been ignoring longstanding legal interpretations that mandate the release of many people who are taken into immigration custody if they post a bond", resulting in lawsuits and many releases. ^[104]

Media campaign

Further information: United States Immigration and Customs Enforcement § Publicity campaign, and ICE recruitment during the second Trump administration

An ICE recruitment poster posted by Homeland Security on X on August 11, 2025 featured the caption "Which way, American man?", a reference to the 1978 book Which Way Western Man? which depicts Jews, Black people, and nonwhite immigrants as an existential threat to the United States. ^[105]

An anti-immigrant World War II-style propaganda poster posted by Homeland Security on X on June 11, 2025, telling readers to report "foreign invaders" to ICE during the Los Angeles protests. The poster was previously circulated by far-right accounts. ^[106]

Amid relatively low numbers of ICE arrests and deportations, Trump's administration sought to inflate the presence of deportations in media, such as by posting images of shackled deportees on social media, manipulating Google searches by updating timestamps of old ICE press releases, and allowing celebrities like Dr. Phil to accompany ICE raids. ^{[92] [107]} Commentators described the media campaign as coming close to "glorifying violence and rough justice" and prioritizing "looking tough". ^[108] The meme-heavy publicity campaign was run by political appointees in their 20s, and received criticism from political commentators and scholars for being unprofessional and intentionally cruel, ^{[109] [110]} and promoting white nationalism, remigration, Nazism, fascism, and antisemitism. ^{[111] [112] [113]}

In February 2025, the White House posted a video on social media showing immigrants in shackles being prepared for a deportation flight, along with footage of a set of handcuffs and chains jingling as they are pulled from a basket and laid out on airport tarmac next to others. The video was captioned "ASMR: Illegal Alien Deportation Flight", and was shared by the Seattle office of ICE, along with a different caption. Responses to the video ranged, with some cheering the actions shown in the video, while others called it disgusting and dehumanizing. ^[114]

Department of Homeland Security video warning featuring Kristi Noem

In March 2025, DHS skipped a competitive bidding process and awarded two Republican-linked firms $200 million to create an anti-migrant ad campaign that praised Trump. The adverts played on television channels and featured Kristi Noem thanking Trump and touting the administration's deportation efforts. The videos drew attention for their use of campaign-style footage of Trump. ^[115]

In late April 2025 the administration posted multiple stylized booking photos along the White House north lawns perimeter with the word 'Arrested' and a severe crime listed beneath an unblurred image. ^[116] The administration claims that the individuals depicted in the signs have all entered the country illegally and were all convicted of severe crimes such as murder, kidnapping, sexual assault of a child and rape. Shortly after the posting of the signs the official White House Twitter account posted photos used in the signs along with the individuals full names. ^[117]

Politico described the administration's legal setbacks on deportation being used as part of a public relations campaign that relied on "oversimplifications" and "misrepresentations" of his legal cases to tell the story of "a president trying to get violent criminals out of the country, only to be blocked by obstinate judges". ^[118]

Conditions in detention

Detainees have reported overcrowded and unsanitary conditions in ICE detention. A group of women was denied access to the bathroom and forced to urinate on the floor of a prison bus on the way to Krome detention center in Florida. Detainees have reported being denied access to food, water, and showers. ^[99]

A September 2025 report in The Guardian on the Alexandria, Louisiana detention center documented overcrowding, substandard conditions, lack of access to medical treatment, stays longer than the three days allowed for short-term facilities, difficulties accessing lawyers and family, indifference from facility staff and other issues. Private company Geo Group runs the Alexandria facility. Geo Group donated US$1 million to Trump-aligned political action committee MAGA Inc. in 2024; ^[119] ICE acting director Tom Homan was a paid consultant to the firm prior to joining the Trump administration. Four days previous to a February 2025 ICE inspection of the facility it was given a waiver from standard medical screening standards for detainees. DHS and Geo Group representatives denied that there were issues with conditions at the Alexandria detention facility, but without addressing specifics. ^[120] A later report on an ICE detention facility in California City, California, echoed concerns about substandard conditions and alleged detainees who protested were put into solitary confinement. Private company CoreCivic, which reopened and runs the facility, a former state prison that had been closed in March 2024, denied the allegations. In addition to the conditions for detainees, advocates claimed it was being run without the necessary permits or approval process. ^[121]

A September 2025 report from Physicians for Human Rights, the Peeler Immigration Lab and Harvard University Law School experts on solitary confinement in ICE detention facilities showed an escalation under the Trump administration, including for individuals, durations and reasons that violated ICE guidelines as well as international standards for humane detention. ^{[122] [123]} A November 2025 lawsuit alleged inhumane conditions in the Broadview ICE facility outside of Chicago. According to the lawsuit, detainees were denied access to bathrooms, clean beds, legal representation and contact with the outside world. ^[124] An Egyptian political asylee detained by ICE for 10 weeks said that his detention in the United States was as brutal as his detention in Egypt was. ^[125]

An October 2025 report by the American Civil Liberties Union documented numerous cases of ICE detention of pregnant women, in contravention of ICE's own policy against the practice. ^[126] At least 14 pregnant detainees were held at Basile Detention Center in Louisiana as of April 2025. ICE has stopped reporting the number of pregnant people in its custody and refused to hand that information over to Congress. The ACLU documented instances of "miscarriages, denial of prenatal care, and inadequate food and medical attention" faced by pregnant women in immigration detention. ^{[127] [128]}

A December 2025 Amnesty International report found numerous human rights violations at Florida's "Alligator Alcatraz" and Krome detention centers. Violations and abuses identified by Amnesty included arbitrary detention, unsanitary conditions (toilets overflowing, limited access to showers, exposure to insects, 24-hour lighting, poor food and water quality and lack of privacy), and incommunicado detention at Alligator Alcatraz, as well as overcrowding, medical negligence, prolonged arbitrary and retaliatory solitary confinement, violence by guards, including in the presence of human rights monitors, and similarly unsanitary and inhumane detention conditions at Krome. ^{[129] [130]} A leaked January 2026 video showed overcrowded, unsanitary conditions inside an ICE detention center in Baltimore, Maryland. Immigrant rights advocates had raised alarm about conditions in this facility in the spring of 2025. ^{[131] [132]}

Detainees at the CoreCivic-run detention facility in Dilley, Texas wrote letters ^[133] and had family record their video calls ^[134] to draw attention to the conditions and prolonged nature of their detention. This effort helped to publicize the prolonged detention of children at the facility. Detainees said that guards at the facility began confiscating writing and artistic supplies and monitoring detainees' phone calls after information about conditions at the facility became public. ^[135]

Deaths in detention

Main article: List of deaths in ICE detention

By the end of February, at least three people had died in ICE detention centers since the beginning of the Trump presidency. ^[136]

In April 2025, Washington state representative Pramila Jayapal's office raised alarm over the suicide of a Chinese national in CBP custody at Yuma Border Patrol Station. Though her suicide was seen in surveillance footage, CBP could not verify whether required welfare checks were performed and did not render a medical response for nearly two hours. ^[137] On April 16, a 58-year-old Vietnamese refugee with dementia living in Albuquerque died in ICE detention, with his family alleging that he died due to medical neglect. ^[138] On April 25, a Haitian woman who had been detained at Broward Transitional Center died, leading to outcry over her alleged medical neglect. ^[139] Altogether, at least seven people died in ICE custody within the first 100 days of the Trump presidency. ^[140] By mid-May, nine had died, ^[141] including a 68-year-old man who died in transit the month after his confinement when he reportedly had been in good health. ^{[142] [143]}

In June, a 49-year-old Canadian man died in ICE custody. ^[144] By July, 13 had died in ICE custody. ^[145] On August 7, a 32-year-old Chinese citizen was found hanging in his cell in ICE custody in Pennsylvania. ^[146]

On December 3, a 48-year-old man from Guatemala who reportedly had been healthy when detained and sent to Camp East Montana died in an El Paso hospital from liver and kidney complications. Earlier, his widow, who had been separated from him since their detention, had been deported to Guatemala. Amnesty International and other activists have called for the closure of Camp East Montana after multiple reports about conditions there; DHS has denied these reports. ^{[147] [148] [149]} On December 14, a 46-year-old Eritrean man died after seven months in ICE custody in Philipsburg, Pennsylvania. ^[150]

By December 2025, ICE had reported 32 detainee deaths since January 20, compared to 24 such deaths during the four-year presidency of Joe Biden. The higher number of deaths was attributed to increased numbers of detainees, increased reliance on private detention facilities, frequent transfers between facilities and the dismantling of government offices investigating discrimination, neglect and mistreatment in detention. ^{[151] [152]} The number of deaths in ICE detention in 2025 was the highest since 2004. In December, four people died in the span of four days according to ICE press releases. ^[153]

On January 3, 2026, a 55-year-old Cuban man died in ICE detention at Camp East Montana. ^[154] ICE said his death was a suicide, but a witness said he was choked by a guard. ^[155] Subsequently, the medical examiner who assessed his case ruled it a homicide. ^[156] On January 14, 36-year-old Nicaraguan immigrant Victor Manuel Diaz was the third person to die at Camp East Montana after being taken there by ICE from Minnesota. ^[157] In January 2026, 46-year-old Cambodian refugee Parady La died from drug withdrawal in ICE detention in Philadelphia. La's family accused ICE of medical neglect, saying they were told that he was begging for help in the final hours of his life. ^[158]

Geraldo Lunas Campos

This section is an excerpt from Killing of Geraldo Lunas Campos.[ edit ]

On January 3, 2026, 55-year-old Geraldo Lunas Campos died while in Immigration and Customs Enforcement (ICE) custody in Camp East Montana at Fort Bliss in El Paso, Texas. The Department of Homeland Security (DHS) said Lunas Campos had attempted suicide, but witnesses said he died after being restrained by multiple guards. His death was ruled a homicide by the El Paso County Coroner. ^[159]

Detainee characteristics

The Trump administration frequently states detainees targeted by ICE are "the worst of the worst" and violent criminals. The Economist described the claim as having "little basis in reality", with a majority of detainees having no criminal records. ^[160]

NBC News reported that the number of ICE detainees increased from 39,238 to 41,169 over the first two weeks of February 2025. They reported that almost all of the 4,422 new detainees were male, with only 22 females. The report stated that 41% of the new detainees had no criminal charges, compared to 28% under the Biden administration. The report also noted that ICE had the capacity to hold 41,500 people, and new capacity was being sought both in the United States and Guantanamo Bay. ^[161]

In early April 2025, attorneys for Venezuelan immigrants with temporary protected status reported that their clients were being arrested and detained in possible violation of law, including while complying with rules to check in with ICE. ^[162] In May 2025, a group of Venezuelan detainees who had been temporarily blocked from deportation to El Salvador formed an "SOS" by linking their bodies together in the yard of the Bluebonnet Detention Facility. The detainees and their families have rejected government claims that they are gang members and decried the use of the Alien Enemies Act to circumvent the ordinary asylum process. ^[163]

By June 2025, The Independent highlighted released data that indicated non-criminal ICE arrests had jumped more than 800% since April, that only 30% of those in detention had criminal convictions with 27% having pending criminal charges, and only 8.5% of those with criminal records were for violent offenses. The increased non-criminal arrests were described as part of the Trump administration's efforts to ramp up deportations at all costs. ^[13] CNN reported internal ICE statistics showing less than 10% of immigrants in ICE custody since October 2024 had criminal offenses, and stated that internal ICE documents suggested officials were not focused on violent criminals. ^[14] On June 20 2025, the Cato Institute reported on nonpublic data of ICE arrests that indicated 65% detained by ICE had no criminal convictions, and that 93% had no violent convictions. ^[15] A July 2025 analysis of statistics from the Deportation Data Project ^[164] shows that the proportion of immigrants convicted of violent crimes has dropped from the Biden administration's 10% to 7% during the Trump administration, when comparing the period January 20-June 26. ^[165] As of November 30, 2025, 73.6% of detainees had no criminal conviction. Many of the convicted detainees committed only minor defenses such as traffic violations. ^[166]

On January 29, 2026, The Economist reported that while the Trump administration claimed to be targeting "the worst of the worst", only 5% of recent detainees had been convicted of violent crimes. ^[167] At the end of the Biden administration, the percentage of criminals captured by ICE was at 64%, falling to roughly 30% by November 2025. ^[160]

Refugees

In Pennsylvania, 10 Lhotshampa Bhutanese refugees were detained in ICE raids. ^[168] As many as 60 Bhutanese refugees have been detained nationwide. Those detained were afforded refugee status, but ICE pointed to their criminal records, ranging from driving under the influence to felony assault, to justify the revocation of their legal status and their deportation. Many had already served their time in U.S. prisons or on probation and reintegrated into society. ^[169]

Neither Bhutan nor Nepal accepts Lhotshampa refugees as citizens, rendering them stateless when deported from the US. ^[169] Several of those deported were forced to return to refugee camps in Nepal. ^[170]

Children

In February 2025, Reuters reported that ICE planned to locate over 600,000 people who entered the U.S. as children without their parents, some of whom were no longer children and some of whom had rejoined and were living with parents, and either deport them, if deportation had already been ordered, or serve notice to appear in immigration court. ^[171] On March 6, 2025, ICE began to detain immigrant parents and children together in a Texas detention facility. The first group contained 3 minor children. ^[172]

In October 2025, cases emerged where migrant children had been misclassified as unaccompanied or otherwise separated from their parents, who were then moved between several ICE detention facilities. Advocates feared this could lead to indefinite separations should the government lose track of where it was sending parents and their children. ^[173]

Also in October 2025, lawyers for unaccompanied minors in ICE custody began to receive word that their clients would be moved to adult detention facilities after their 18th birthdays. On October 4, U.S. District Judge Rudolph Contreras issued a temporary restraining order finding that ICE policy in violation of his 2021 order directing that such minors be released to the least restrictive setting available on turning 18 as long as they were not a danger to themselves or others and/or a flight risk. ^[174]

Liam Conejo Ramos

This section is an excerpt from Detention of Liam Conejo Ramos.[ edit ]

Liam with his father after having been released

On January 20, 2026, US Immigration and Customs Enforcement (ICE) agents detained Liam Conejo Ramos, a five-year-old boy, on his walk home from school in Columbia Heights, Minnesota, amid the Operation Metro Surge deployment to the Minneapolis–Saint Paul metropolitan area. The child and his father Adrian Conejo Arias each had an active claim for asylum in the United States and were arrested in their driveway. According to witness statements and the family's attorney, there were multiple adults available to take custody of Liam, but ICE arrested him anyway. ^[175]

According to Spain's El País newspaper, "Images of [Conejo Ramos], wearing his blue hat and carrying a Spider-Man backpack, guarded by federal agents, instantly became a symbol of the indiscriminate nature of President Donald Trump’s immigration crackdown in the United States". ^[176]

Adrian Conejo Arias and his five-year-old son, Liam, were apprehended by Immigration and Customs Enforcement (ICE) in Minnesota in January 2026 as part of a federal immigration enforcement action. The detention of Adrian and his son, which was documented in a photograph that went viral, gained significant attention as a representation of the increased deportation actions in Minnesota under the Trump administration. ^{[177] [178]}

Later, a federal judge named Fred Biery ordered the release of the child and his father, denouncing the deportation policies of the administration as inhumane and illegal. The judge’s decision highlighted that the judiciary had to intervene to prevent further suffering for the family and that the Department of Homeland Security had to release them by February 3, 2026. This issue was mentioned in relation to the judiciary’s reaction to the detention of children and the treatment of minors in immigration enforcement. ^[179]

Citizen detentions

This section is an excerpt from Immigration detentions of U.S. citizens in the second Trump administration.[ edit ]

El País and The Fresno Bee compared the second Trump administration's immigration detention policies to the Internment of Japanese Americans during World War II (pictured).

Immigration detentions of U.S. citizens in the second Trump administration were caused by U.S. immigration enforcement actions by agencies including Immigration and Customs Enforcement (ICE) and U.S. Customs and Border Protection (CBP) and involved documented cases in which American citizens were stopped, detained, arrested, or held in custody in connection with immigration operations. ^{[182] [183]} Reporting based on official records and court filings has described incidents in which enforcement personnel detained people without first confirming citizenship status, and in which citizens were allegedly subjected to enforcement actions later challenged as unlawful or unsupported by accurate official narratives. ^{[182] [184] [185] [186]}

Because the federal government did not maintain a comprehensive public count of citizen detentions, totals have largely been reconstructed through investigative reporting and litigation; ProPublica reported at least 170 citizen detentions through October 2025 and described cases involving alleged force and multi-day detention without access to counsel or communication. ^[183] Commentators and advocacy groups have argued that the pattern of detentions reflects racial profiling and has contributed to some citizens carrying passports or other proof of citizenship within the United States despite there being no general legal requirement to do so. ^{[182] [180] [187]} Incidents involved public officials and oversight activity. On September 18, 2025, multiple New York City and New York State elected officials were arrested and detained by ICE while seeking access to inspect immigration holding cells described in court proceedings as unsanitary and overcrowded. ^{[188] [189]} Other reported cases have involved citizens detained during street encounters, workplace actions, and protests, including military veterans arrested during demonstrations against ICE activity. ^{[183] [190] [191]}

See also

• 2025 Alvarado ICE facility incident
• 2025 Dallas ICE facility shooting
• List of immigrant detention sites in the United States
• Prisoner rights in the United States

References

1. Houghtaling, Ellie Quinlan (January 22, 2025). "Trump's Immigration Plans Are Already Wrecking the Food Industry". The New Republic . ISSN   0028-6583 . Retrieved 2025-01-23.
2. Santana, Rebecca (2025-01-21). "Trump administration throws out policies limiting migrant arrests at sensitive spots like churches". Associated Press . Retrieved 2025-01-23.
3. Aguilar, Julian (November 23, 2024). "Trump's deportation vow alarms Texas construction industry". NPR.
4. Yeğinsu, Ceylan (2026-02-20). "11 Million Visitors Short: Inside America's Continuing Tourism Slump". The New York Times. ISSN   0362-4331 . Retrieved 2026-02-27.
5. Anderson, Brett; Rao, Tejal; Wilson, Korsha (2025-01-25). "As Immigration Crackdown Looms, Restaurants Are Racked With Fear". The New York Times. ISSN   0362-4331 . Retrieved 2025-01-29.
6. Fadel, Leila (2025-07-10). "Masked immigration agents are spurring fear and confusion across the U.S." NPR . Retrieved 2025-10-17.
7. Green, Rick; Sentinel, Keene (2025-10-16). "NH bill would prohibit masked police officers during ICE raids". New Hampshire Public Radio . Retrieved 2025-10-17.
8. Rossiter, Emma (2025-09-21). "California bans most law enforcement including ICE from wearing masks". www.bbc.com. Retrieved 2025-10-17.
   
   See also: No Secret Police Act
9. Diaz, Jaclyn (September 19, 2025). "What ICE agents can and cannot legally do during arrests". NPR .
10. Aleaziz, Hamed; Rosenberg, Carol (January 29, 2025). "Trump Says U.S. Will Hold Migrants at Guantánamo" . The New York Times .
11. "Guantanamo could be used to hold up to 30,000 migrants". ABC News. January 29, 2025.
13. Hagopian, Alicja (June 23, 2025). "ICE is arresting more non-criminals than ever: Just 8% of detainees have serious criminal records". The Independent. Retrieved June 23, 2025.
14. Tolan, Casey; Devine, Curt; Alvarez, Priscilla; Kamp, Majlie de Puy; Abou-Ghazala, Yahya (June 16, 2025). "Less than 10% of immigrants taken into ICE custody since October had serious criminal convictions, internal data shows". CNN. Retrieved June 23, 2025.
15. Bier, David J. (June 20, 2025). "65 Percent of People Taken by ICE Had No Convictions, 93 Percent No Violent Convictions" . Cato Institute . Retrieved June 23, 2025. New nonpublic data from Immigration and Customs Enforcement (ICE) indicate that the government is primarily detaining individuals with no criminal convictions of any kind. Also, among those with criminal convictions, they are overwhelmingly not the violent offenses that ICE continuously uses to justify its deportation agenda. ICE has shared this data with people outside the agency, who shared the numbers with the Cato Institute.
16. "Courts Have Ruled 4,400+ Times That ICE Jailed People Illegally; Despite Rebukes, ICE Keeps Doing It". Democracy Now!. Retrieved 2026-02-25.
17. Danner, Chas (May 3, 2025). "All the U.S. Citizens Who've Been Caught Up in Trump's Immigration Crackdown". New York . Archived from the original on 2025-04-30. Retrieved May 4, 2025. It's not a matter of if U.S. citizens are getting caught up in President Donald Trump's immigration crackdown and mass-deportation efforts but, rather, how and how many. Some have just been collateral arrests and detentions, in which people are briefly questioned or detained by ICE agents, while others have been jailed for hours or days. Some U.S.-born children have been swiftly deported along with undocumented family members.
18. "Could ICE have 'lost' 3,000 immigrant arrestees in Chicago?". NBC Chicago.
19. Palmer, Kathryn (November 3, 2025). "Will ICE raids get worse? Trump says they 'haven't gone far enough'". USA Today. Retrieved November 10, 2025.
20. Tareen, Sophia (October 6, 2025). "Using helicopters and chemical agents, immigration agents become increasingly aggressive in Chicago". AP News. Retrieved November 10, 2025.
21. "Tear gas and Halloween costumes in America's third-largest city" . The Economist. October 29, 2025. Retrieved November 10, 2025.
22. Schneid, Rebecca (October 4, 2025). "'Military-Style' ICE Raid On Chicago Apartment Building Shows Escalation in Trump's Crackdown". TIME . Retrieved November 10, 2025.
23. Timotija, Filip (January 23, 2025). "NJ mayor slams 'egregious' ICE raid: 'Newark will not stand by idly'". The Hill. Retrieved 24 January 2025.
24. "ICE agents arrest hundreds of migrants in sanctuary cities, including New York City". WABC-TV. January 23, 2025. Retrieved 24 January 2025.
25. Sobko, Katie (23 January 2025). "ICE raids establishment in Newark, detains undocumented residents". North Jersey Media Group . Retrieved 24 January 2025.
26. Kelly, Josh; Smith, Jessie Christopher; Cuevas, Eduardo (2025-05-01). "Right house, wrong people, DHS admits, after raiding home of US citizens". USA Today. Retrieved 2025-05-19.
27. Golden, Hallie (September 6, 2025). "What to know about a large-scale immigration raid at a Georgia manufacturing plant". AP News . Retrieved September 7, 2025.
28. "What We Know About the Hyundai-LG Plant Immigration Raid in Georgia". New York Times . September 7, 2025. Retrieved September 7, 2025.
29. Wolfe, Rachel (September 7, 2025). "Hyundai Raid Rattles a Hot Spot of Growth in Georgia". The Wall Street Journal. Retrieved 2025-09-08.
30. Riddle, Safiyah; Gonzalez, Valerie (January 13, 2026). "What to know about the warrants most immigration agents use to make arrests". Associated Press. Retrieved January 22, 2026.
31. Watson, Julie; Taxin, Amy (January 23, 2026). "Immigrants often don't open the door to ICE, but that may no longer stop officers". Associated Press. Retrieved January 23, 2026.
32. Santana, Rebecca (January 21, 2026). "Immigration officers assert sweeping power to enter homes without a judge's warrant, memo says". Associated Press. Retrieved January 21, 2026.
33. Montoya-Galvez, Camilo (January 21, 2026). "Internal memo authorizes ICE to enter homes without judicial warrants in some cases". CBS News. Retrieved January 21, 2026.
34. Strickler, Laura; Helsel, Phil (January 21, 2026). "ICE says its officers can forcibly enter homes during immigration operations without judicial warrants: 2025 memo". NBC News. Retrieved January 21, 2026.
35. Williams, Michael (January 22, 2026). "New ICE policy allows officers to enter homes without a judge's warrant. Here's what experts say". CNN. Retrieved January 23, 2026.
36. Barr, Luke (January 22, 2026). "ICE memo allows agents to enter homes without judicial warrant: Whistleblower complaint". ABC News. Retrieved January 23, 2026.
37. Raymond, Nate (January 30, 2026). "Lawsuit challenges ICE ability to enter homes without warrants from US judges". Reuters. Thomson Reuters. Retrieved January 30, 2026.
38. Betancourt, Sarah (January 30, 2026). "Mass. advocates sue ICE over warrantless home entry policy". WGBH . Retrieved January 30, 2026.
39. CRS 2025b, pp. 1–2.
40. 8 U.S.C.   § 1226
41. CRS 2025b, p. 2.
42. 8 U.S.C.   § 1357
43. Montoya-Galvez, Camilo (January 31, 2026). "New ICE memo gives deportation officers more leeway to conduct warrantless arrests". CBS News. Retrieved February 3, 2026.
44. Rivera, Mark; Markoff, Barb; Tressel, Christine; Jones, Tom (February 2, 2026). "ICE memo gives agents broad authority to arrest those they believe are undocumented without warrant". WLS . Retrieved February 3, 2026.
45. Rush, Claire (February 4, 2026). "ICE agents can't make warrantless arrests in Oregon unless there's a risk of escape, US judge rules". Associated Press. Retrieved February 4, 2026.
46. Santamaria, Kelsey Y.; Smith, Hillel R. (March 30, 2021). Searches and Seizures at the Border and the Fourth Amendment (Report). Congressional Research Service. pp. 2–3, 28–45. Retrieved January 23, 2026.
47. CRS 2025b, pp. 2–3.
48. CRS 2025b, p. 3.
49. CRS 2025b, p. 4.
50. CRS 2025b, pp. 4–5.
51. Burke, Garance; Tau, Byron (January 30, 2026). "DHS ramps up surveillance in immigration raids, sweeping in citizens". Associated Press. Retrieved January 30, 2026.
52. Cox, Joseph (June 26, 2025). "Facial Recognition App to Identify People, Leaked Emails Show". 404 Media. Retrieved February 3, 2026.
53. Mansoor, Sanya (January 27, 2026). "How ICE is using facial recognition in Minnesota". The Guardian. Retrieved January 30, 2026.
54. Frenkel, Sheera; Krolik, Aaron (January 30, 2026). "How ICE Already Knows Who Minneapolis Protesters Are". The New York Times. Retrieved February 3, 2026.
55. Smith, Micah (February 2, 2026). "Concerns grow over federal agencies use of facial recognition technology on protesters". KMGH . Retrieved February 3, 2026.
56. Joffe-Block, Jude (November 8, 2025). "Immigration agents have new technology to identify and track people". NPR. Retrieved January 30, 2026.
57. GAO 2020, pp. 38–41.
58. CRS 2020, pp. 7–8.
59. CRS 2020, pp. 8–9.
60. FACIAL RECOGNITION TECHNOLOGY: Federal Agencies' Use and Related Privacy Protections (PDF) (Report). Government Accountability Office. June 29, 2022. p. 4. Retrieved February 2, 2026.
61. GAO 2020, pp. 41–44.
62. CRS 2020, pp. 9–10.
63. Kolker, Abigail F. (May 2, 2023). Immigration: The U.S. Entry-Exit System (Report). Congressional Research Service. pp. 3–4. Retrieved February 2, 2026.
64. CRS 2020, p. 8.
65. CRS 2020, p. 10.
66. CRS 2020, pp. 11–13.
67. CRS 2020, pp. 13–14.
68. CRS 2020, pp. 15–16.
69. CRS 2020, pp. 5–7, 14–15.
70. CRS 2020, pp. 16–18.
71. CRS 2020, pp. 18–21.
72. CRS 2020, pp. 21–23.
73. CRS 2020, pp. 23–27.
74. CRS 2025c, pp. 4–5.
75. CRS 2025c, pp. 5–6.
76. "Bondi letter to Walz requests access to Minnesota voting and welfare records, repeal of 'sanctuary' policies". KSTP. January 25, 2026. Archived from the original on January 25, 2026. Retrieved January 25, 2026.
77. Suter, Tara (January 25, 2026). "Bondi outlines terms for Walz to 'restore the rule of law' in Minnesota after fatal shooting: Reports". The Hill. Nexstar Media Group. Retrieved January 25, 2026.
78. Wendler, Jacob (January 25, 2026). "Trump calls on Congress to pass legislation ending sanctuary policies". Politico. Axel Springer SE. Retrieved January 29, 2026.
79. Karnowski, Steve (January 26, 2026). "Bovino is set to leave Minneapolis as Trump reshuffles the leadership of his immigration crackdown". Associated Press. Retrieved January 26, 2026.
80. Gerstein, Josh; Cheney, Kyle (January 26, 2026). "Trump, Bondi statements fuel legal case against Minnesota surge". Politico. Axel Springer SE. Retrieved January 29, 2026.
81. CRS 2025a, pp. 2–8, 10–14.
82. CRS 2025c, p. 3.
83. CRS 2025b, pp. 2, 5.
84. 8 U.S.C.   § 1357
85. CRS 2025a, pp. 1–2, 8–10, 15–17.
86. Aramayo, Alejandra; Kandel, William A.; Kolker, Abigail F. (March 4, 2025). "Sanctuary" Jurisdictions: Policy Overview (Report). Congressional Research Service. Retrieved January 28, 2026.
87. Holmes, Eric N. (October 31, 2024). Application of the Bill of Rights to the States Through the Fourteenth Amendment and Selective Incorporation (Report). Congressional Research Service. pp. 1–3. Retrieved January 29, 2026.
88. CRS 2025c, p. 4.
89. 8 U.S.C.   § 1373
90. Killion, Victoria L. (July 1, 2021). "Funding Conditions: Constitutional Limits on Congress's Spending Power". Congressional Research Service. pp. 23–24. Retrieved January 28, 2026.
91. "ICE struggles to boost arrest numbers despite infusion of resources". The Washington Post. 15 February 2025.
92. Ward, Myah; Piper, Jessica (4 February 2025). "Mass deportations haven't arrived but Trump's PR blitz has". Politico. Retrieved February 8, 2025.
93. "Scoop: Trump's immigration arrests appear to lag Biden's". Axios. 14 February 2025.
94. "Trump officials issue quotas to ICE officers to ramp up arrests". The Washington Post. 26 January 2025.
95. "Stephen Miller and Kristi Noem demand ICE agents up arrests to 3,000 a day". The Independent. 2025-05-28. Retrieved 2025-06-04.
96. Olivares, José (June 4, 2025). "US immigration officers ordered to arrest more people even without warrants". The Guardian. Retrieved June 23, 2025.
97. Hopkins, Jason (2025-03-12). "'Purposely Misleading': Trump Officials Accuse Biden Admin Of Deceptively Inflating ICE Arrest Stats". MSN . Retrieved 2025-04-04.
98. "Three deaths in ICE custody in just over a month of Trump's presidency marks the most deaths to occur in this fiscal year time period in five years". Detention Watch Network. 26 February 2025. Retrieved 22 March 2025.
99. Villagran, Lauren. "Immigrant women describe 'hell on earth' in ICE detention". USA Today. Retrieved 2025-03-27.
100. "Matter of Jonathan Javier YAJURE HURTADO, Respondent". www.justice.gov. US Department of Justice. Retrieved 25 September 2025.
101. "BIA Decision Strips Immigration Judges of Bond Authority, All but Guaranteeing Mandatory Detention for Undocumented Immigrants". www.americanimmigrationcouncil.org. American Immigration Council. Retrieved 25 September 2025.
102. "AILA: BIA's Decision Ignores Decades of Precedent, Stripping Immigration Judges of Bond Authority". www.aila.org. American Immigration Lawyers Association. Retrieved 25 September 2025.
103. Pratt, Timothy (25 September 2025). "Petition by man against Ice custody may provide new path to release for others". The Guardian. Retrieved 25 September 2025.
104. Mirian, Jordan; Barrett, Devlin (February 1, 2026). "Federal Courts Undercut Trump's Mass Deportation Campaign" . The New York Times. Retrieved February 7, 2026.
106. Duffy, Claire; Lyngaas, Sean; Maruf, Ramishah (June 12, 2025). "DHS posted an image calling for help locating 'all foreign invaders.' It was previously circulated by far-right accounts". CNN. Retrieved June 12, 2025.
107. Kerr, Dara (February 6, 2025). "US immigration is gaming Google to create a mirage of mass deportations". The Guardian . pp. February 8, 2025.
108. Collinson, Stephenson (July 1, 2025). "Trump's visit to a migrant camp called 'Alligator Alcatraz' stirs dark echoes". CNN. Retrieved September 6, 2025. Some come close to glorifying violence and rough justice. At times, it seems like looking tough is even more important than being tough; the posturing may be compensating for a deportation rate that senior White House officials such as Stephen Miller have deemed disappointing.
109. Joffe-Block, Jude; Bond, Shannon (August 18, 2025). "What's behind the Trump administration's immigration memes?". NPR. Retrieved September 6, 2025.
110. Owen, Tess (August 12, 2025). "The Trump Administration Is Using Memes to Turn Mass Deportation Into One Big Joke" . Wired. Retrieved September 6, 2025.
111. Novak, Matt (October 15, 2025). "Border Patrol Posts Instagram Propaganda Video Featuring Antisemitic Slurs". Gizmodo. Retrieved October 16, 2025.
112. Kieffer, Caleb; Cravens, R.G. (August 28, 2025). "Homeland Security deploys white nationalist, anti-immigrant graphics to recruit". Southern Poverty Law Center. Retrieved September 6, 2025.
113. Williams, Michael (August 13, 2025). "On social media, the Department of Homeland Security appeals to nostalgia — with motifs of White identity". CNN. Retrieved September 6, 2025.
114. Mangan, Dan (2025-02-18). "White House posts video of immigrants in shackles, calls deportation footage 'ASMR'". CNBC. Retrieved 2025-02-20.
115. Lixon, Adriana Gomez (March 11, 2025). "How the White House hired Republican political firms to launch an anti-migrant ad campaign". The Associated Press. Retrieved June 23, 2025.
116. Jansen, Swapna Venugopal Ramaswamy and Bart. "Mugshot posters of immigrant arrests line the driveway of White House". USA Today. Retrieved 2025-06-10.
117. Watson, Kathyrn (2025-04-28). "White House lawn lined with mugshot-style posters showing arrested immigrants, alleged crimes". CBS News. Retrieved 2025-04-29.
118. Ward, Myah; Cheney, Kyle (May 23, 2025). "Trump uses legal setbacks on mass deportation for public relations". Politico. Retrieved July 7, 2025.
119. "Geo Group Profile". www.opensecrets.org. Retrieved 12 September 2025.
120. Laughland, Oliver; Craft, Will; Amjad, Raima (12 September 2025). "Trump's deportation hub: inside the 'black hole' where immigrants disappear". The Guardian. Retrieved 12 September 2025.
121. Levin, Sam (27 September 2025). "'Hell on earth': immigrants held in new California detention facility beg for help". The Guardian. Retrieved 27 September 2025.
122. Anguiano, Dani (17 September 2025). "Ice puts more than 10,000 people in solitary in a year – and figures are rising under Trump". The Guardian. Retrieved 17 September 2025.
123. "Cruelty Campaign: Solitary Confinement in U.S. Immigration Detention" (PDF). phr.org. Physicians for Human Rights. September 2025. Retrieved 17 September 2025.
124. Byrnes, Dave (2025-11-03). "Lawsuit Alleges Inhumane Conditions at Broadview ICE Facility". South Side Weekly. Retrieved 2025-11-07.
125. Starr, Stephen (2025-09-25). "'I was reborn': Cincinnati imam reflects on 10 weeks in Ice custody after release". The Guardian. ISSN   0261-3077 . Retrieved 2025-11-17.
126. "ACLU Says ICE Violates Policy Against Jailing Pregnant People and Nursing Moms". Democracy Now!. Retrieved 2025-12-13.
127. "Pregnant women describe miscarrying and bleeding out while in ICE custody, advocates say". NBC News. 2025-10-22. Retrieved 2025-12-13.
128. Strum, Lora (2025-10-27). "Pregnant Women in ICE Detention Suffer Miscarriages, Neglect". American Civil Liberties Union. Retrieved 2025-12-13.
129. "USA: New Findings Reveal Human Rights Violations at Florida's "Alligator Alcatraz" and Krome Detention Centers". Amnesty International. 2025-12-04. Retrieved 2025-12-11.
130. "Torture & Enforced Disappearances at Florida's ICE Jails: Amnesty International Report". Democracy Now!. Retrieved 2025-12-11.
131. "Viral video shows overcrowded conditions inside ICE facility in MD". Maryland Daily Record. 28 January 2026.
132. "Maryland lawmaker describes "horrendous" conditions inside Baltimore ICE facility, speaks out after viral overcrowding video - CBS Baltimore". www.cbsnews.com. 2026-02-01. Retrieved 2026-02-04.
133. Yar, Mica Rosenberg, Anna Donlan, Shoshana Gordon, and Cengiz (2026-02-09). ""I Have Been Here Too Long": Read Letters from the Children Detained at ICE's Dilley Facility". ProPublica. Retrieved 2026-02-27.
134. Rosenberg, Mica (2026-02-09). "The Kids Trump Sent to ICE's Dilley Detention Center". ProPublica. Retrieved 2026-02-27.
135. Rosenberg, McKenzie Funk and Mica (2026-02-26). "Seized Art, Eavesdropping Guards: Parents Describe a Clampdown at Dilley Detention Center as Kids Shared Their Stories". ProPublica. Retrieved 2026-02-27.
136. "Three deaths in ICE custody in just over a month of Trump's presidency marks the most deaths to occur in this fiscal year time period in five years". ACLU of Florida. 2025-03-05. Retrieved 2025-04-04.
137. Jeske, Sam (2025-04-02). "Jayapal Statement on Death of Detained Person at Yuma Border Patrol Station". Congresswoman Pramila Jayapal. Retrieved 2025-04-04.
138. "Family Says Vietnamese Refugee with Dementia Died of Medical Neglect After Arrest by ICE". Democracy Now!. Retrieved 2025-05-09.
139. Treisman, Rachel (2025-05-01). "Lawmakers demand answers after a Haitian woman dies at an ICE detention center". NPR. Retrieved 2025-05-03.
140. Nagovitch, Paola (2025-05-05). "Lives cut short in ICE custody: Seven migrants die in Trump's first 100 days". El País English. Retrieved 2025-05-09.
141. Jansen, Bart. "Trump official acknowledges 9 detainee deaths in ICE custody, disputes overspending". USA Today. Retrieved 2025-06-04.
142. Free, Andrew (12 June 2025). "A 68-year-old grandfather died in ICE's custody. His family seeks answers". Atlanta Community Press Collective. Retrieved 22 June 2025.
143. Pratt, Timothy (22 June 2025). "'Ticking time bomb': Ice detainee dies in transit as experts say more deaths likely". The Guardian. Retrieved 22 June 2025.
144. Caruso-Moro, Luca; Chaya, Lynn (June 26, 2025). "Canada 'urgently seeking more information' on death of Canadian in ICE custody". CTV. Retrieved June 27, 2025.
145. "Two more Ice deaths put US on track for one of deadliest years in immigration detention". The Guardian.
146. "ICE detainee found hanging by neck in detention facility, agency says". ABC News. Retrieved 2025-08-07.
147. "Detained Immigrants Detail Physical Abuse and Inhumane Conditions at Largest Immigration Detention Center in the U.S." ACLU. December 8, 2025. Retrieved 2025-12-13.
148. Abbott, Jeff (19 December 2025). "Exclusive: She survived ICE custody; her husband died during detention". El Paso Times. Retrieved 28 December 2025.
149. Abbott, Jeff (20 December 2025). "Exclusive: 911 calls from migrant detention center highlight dire conditions". El Paso Times. Retrieved 28 December 2025.
150. Pallotto, Bret (2025-12-19). "Another man dies at ICE facility near Philipsburg. Advocates renew calls for closure". Centre Daily Times . Retrieved 2025-12-21.
151. "During a deadly year for ICE detention, man dies at Michigan's newest facility". MLive.
152. Bustillo, Ximena; Mukherjee, Rahul (October 23, 2025). "It's the deadliest year for people in ICE custody in decades; next year could be worse". NPR News. Retrieved November 10, 2025.
153. "ACLU Sounds Alarm over Surge of Deaths of Immigrants Jailed by ICE". Democracy Now!. Retrieved 2025-12-29.
154. Martinez, Jeff Abbott and Aaron. "Cuban immigrant's death at Camp East Montana likely 'homicide'". El Paso Times. Retrieved 2026-01-20.
155. Biesecker, Michael; Attanasio, Cedar; español, RYAN J. FOLEY Leer en (2026-01-16). "ICE says Cuban immigrant died while attempting suicide. A witness says guards pinned and choked him". AP News. Retrieved 2026-01-18.
156. "Medical examiner set to rule ICE detainee's death a homicide - report". The Independent. 2026-01-16. Retrieved 2026-01-18.
157. Abbott, Jeff. "Nicaraguan man arrested by ICE in Minnesota dies at Camp East Montana". El Paso Times. Retrieved 2026-01-20.
158. "Family questions treatment of Cambodian immigrant who died in ICE custody in Philadelphia". 6abc Philadelphia. 2026-01-12. Retrieved 2026-01-13.
159. Biesecker, Michael; Foley, Ryan J. (January 21, 2026). "Autopsy finds Cuban immigrant in ICE custody died of homicide due to asphyxia". The Associated Press. Retrieved January 23, 2026.
160. "Immigration agents have become Donald Trump's personal posse" . The Economist. January 28, 2026. Retrieved February 7, 2026.
161. Strickler, Laura (February 19, 2025). "New Immigration and Customs Enforcement data shows administration isn't just arresting criminals". NBC News.
162. Villarreal, Alexandra (5 April 2025). "Venezuelans with legal status are being illegally detained in the US, lawyers say". The Guardian. Retrieved 5 April 2025.
163. "Migrants form SOS sign in Texas detention center, fear notorious El Salvador prison". NBC News. 2025-05-01. Retrieved 2025-05-04.
164. "Deportation Data Project". deportationdata.org. Archived from the original on 2025-07-18. Retrieved 2025-08-05.
165. Henderson, Tim (2025-07-24). "Fewer than half of ICE arrests under Trump are convicted criminals". Stateline. Archived from the original on 2025-07-24. Retrieved 2025-08-05.
166. "Immigration Quick Facts". Trac Reports. Retrieved 2026-01-12.
167. "ICE's impunity is a formula for more violence" . The Economist. January 29, 2026. Retrieved February 7, 2026.
168. "Gov. Josh Shapiro supports Lhotshampa Bhutanese refugees in face of ICE arrests". WITF. 2025-03-25. Retrieved 2025-05-17.
169. Streeter, Kurt (2025-05-01). "U.S. Deported Bhutanese Who Were Here Legally. They Are Now Stateless". The New York Times. ISSN   0362-4331 . Retrieved 2025-05-17.
170. Dhungana, Dipendra (2025-04-24). "Deported Bhutanese Refugees from the U.S. Allowed to Return to Original Camps in Nepal". NEPYORK. Retrieved 2025-05-17.
171. Taylor, Marisa; Hesson, Ted; Cooke, Kristina (2025-02-23). "Trump officials launch ICE effort to deport unaccompanied migrant children". Reuters.
172. Montoya-Galvez, Camilo (March 7, 2025). "Trump revives practice of detaining migrant families with children". CBS News.
173. Singh, Maanvi (2 October 2025). "Trump revives family separations amid drive to deport millions: 'A tactic to punish'" . Retrieved 5 October 2025.
174. Amy, Jeff (4 September 2025). "Judge blocks Trump policy to detain migrant children turning 18 in adult facilities". Associated Press. Retrieved 5 October 2025.
175. WATCH: Lawyer for 5-year-old boy detained by ICE holds news conference . Retrieved 2026-01-30– via www.youtube.com.
176. Jank Curbelo, Jesús; Leal, Nicholas Dale (2026-01-27). "Liam Conejo Ramos: The face of the hundreds of minors in immigration custody under the Trump administration". EL PAÍS English. Retrieved 2026-01-28.
177. Mulvihill, Geoff (February 1, 2026). "Judge orders 5-year-old Liam Conejo Ramos and his dad released from ICE detention". AP News.
178. Murphy Marcos, Coral (January 31, 2026). "Judge orders release of five-year-old Liam Conejo Ramos and father from ICE detention". The Guardian.
179. Cheney, Kyle (2026-01-31). "Judge orders release of 5-year-old detained by ICE in Minnesota". Politico.
180. Montalvo, Melissa (2025-08-03). "Some Californians carry passports in fear of ICE. 'We're being racially profiled'". Fresno Bee . Archived from the original on August 4, 2025. Retrieved February 20, 2026.
181. Beauregard, Luis Pablo (2025-04-22). "Camp Manzanar serves as a reminder to the United States of racist laws in other eras". El País . Archived from the original on 2025-04-23.
182. Bier, David J. (2025-08-05). "One in Five ICE Arrests Are Latinos on the Streets with No Criminal Past or Removal Order". Cato Institute . Archived from the original on 2025-08-07.
183. Foy, Nicole (2025-10-16). "We Found That More Than 170 U.S. Citizens Have Been Held by Immigration Agents. They've Been Kicked, Dragged and Detained for Days". ProPublica . Archived from the original on 2025-10-16.
184. Queally, James; Mejia, Brittny (2025-07-23). "Trump's top federal prosecutor in L.A. struggles to secure indictments in protest cases". Los Angeles Times . Archived from the original on 2025-07-28.
185. Levin, Sam (2025-07-28). "Justice department drops cases against LA protesters after officers caught making false claims". The Guardian. Archived from the original on 2025-07-28.
186. Castle, Cerise (2025-08-01). "Border Patrol and ICE Agents Are Arresting U.S. Citizens in Immigration Raids". Capital & Main. Archived from the original on 2025-08-06.
187. Tabafunda, James (2025-08-13). "Proof of belonging: Asian American citizens carry passports amid ICE fears". Northwest Asian Weekly . Archived from the original on 2025-08-14.
188. Cameron, Dell (2025-09-18). "These Are the 15 New York Officials ICE and NYPD Arrested in Manhattan; More than a dozen elected officials were arrested in or around 26 Federal Plaza in New York City, where ICE detains people in what courts have ruled are unsanitary conditions". Wired . Archived from the original on September 18, 2025. Retrieved February 20, 2026. Police arrested more than a dozen New York state and city elected officials Thursday at 26 Federal Plaza, the Manhattan immigration court and an Immigration and Customs Enforcement (ICE) field office, many as they pressed to gain access to the building's 10th-floor lockup, where recent court rulings—including a temporary restraining order—directed ICE not to cram immigrants into overcrowded, unsanitary conditions.

     The lawmakers and other officials, arrested around 3:45 pm local time, say they were "attempting to conduct oversight" following claims that people appearing for court hearings were being confined for hours or days without proper food, medical care, or contact with attorneys.

189. Ferré-Sadurní, Luis; Parnell, Wesley; Latson, Samantha (2025-09-18). "11 N.Y. Officials Arrested Trying to Access ICE Detention Cells". New York Times . Archived from the original on 2025-09-18. Federal officers arrested 11 Democratic elected officials inside a federal building in Lower Manhattan on Thursday after the officials demanded access to cells used by the Immigration and Customs Enforcement agency to detain migrants.

     The officials, including Brad Lander, the city comptroller, and city and state lawmakers, were arrested after they showed up at 26 Federal Plaza and sought to inspect the 10th-floor holding cells, which are operated by ICE and closed to the public. The cells have drawn scrutiny following complaints of unsanitary and overcrowded conditions, leading a federal judge to order ICE to improve the conditions last month.

190. Glantz, Aaron (13 October 2025). "Growing number of US veterans face arrest over Ice raid protests". The Guardian. Retrieved 13 October 2025.
191. Tareen, Sophia (2025-03-17). "ICE violated rights of a US citizen and 21 others during arrests, Chicago activists allege". Associated Press . Archived from the original on 2025-03-18.

Works cited

• FACIAL RECOGNITION TECHNOLOGY: Privacy and Accuracy Issues Related to Commercial Uses (PDF) (Report). Government Accountability Office. July 13, 2020. Retrieved February 2, 2026.
• Santamaria, Kelsey Y. (September 24, 2020). Facial Recognition Technology and Law Enforcement: Select Constitutional Considerations (Report). Congressional Research Service. Retrieved February 2, 2026.
• Aramayo, Alejandra (May 6, 2025). Federal Preemption and State Authority to Deter the Presence of Unlawfully Present Aliens: An Overview and Issues for the 119th Congress (Report). Congressional Research Service. Retrieved January 28, 2026.
• Smith, Hillel R. (June 13, 2025). Immigration Arrests in the Interior of the United States: A Primer (Report). Congressional Research Service. Retrieved January 22, 2026.
• Aramayo, Alejandra (September 15, 2025). "Sanctuary" Jurisdictions: Legal Overview (Report). Congressional Research Service. Retrieved January 28, 2026.