Lawsuit targets secret ICE home‑entry policy from Metro Surge
Plaintiffs have sued the Department of Homeland Security in federal court in Washington, D.C., alleging ICE circulated a secret “Home Entry Memo” titled “Utilizing Form I‑205, Warrant of Removal” that instructors showed in secret, used to train inexperienced agents, and led to forced entries and warrantless searches of homes. They seek vacatur of the memo, a declaration that the practice violates the Fourth Amendment, and ongoing injunctive relief, with ACLU of Minnesota and Protect Democracy attorneys saying the policy was a deliberate end‑run around the Constitution.
📌 Key Facts
- The lawsuit challenges an internal "Home Entry Memo" titled "Utilizing Form I‑205, Warrant of Removal," which plaintiffs allege instructed agents to rely on Form I‑205 to enter homes instead of obtaining judicial warrants.
- Whistleblowers say ICE instructors showed the memo "in secret," told trainees not to take notes, and primarily used it to train inexperienced recruits.
- Plaintiffs describe forced home entries in which agents allegedly pushed past residents and searched homes without judicial warrants.
- The complaint seeks formal vacatur of the Home Entry Memo, a judicial declaration that the practice is unconstitutional, and ongoing injunctive relief to prevent future use.
- The lawsuit was filed in federal court in Washington, D.C., directly targeting DHS headquarters rather than only local ICE operations.
- Attorneys from ACLU of Minnesota and Protect Democracy characterize the policy as a deliberate end‑run around the Fourth Amendment, not a misunderstanding.
📊 Relevant Data
During Operation Metro Surge from December 2025 to mid-March 2026, ICE made 4,030 arrests in Minnesota, with 63 percent (2,532 arrests) of those arrested having no criminal records.
Most Arrested by ICE in Minnesota Surge Had No Criminal Records — The Intercept
In Operation Metro Surge, arrests by nationality included 1,026 from Ecuador, 885 from Mexico, and 106 from Somalia, with Ecuador having the highest number despite claims of targeting Somalis.
Ecuador's homicide rate reached 44.5 per 100,000 people in 2025, the highest in South America, contributing to increased migration due to violence from drug trafficking and political instability.
2025 Country Conditions: Ecuador — USCRI
The Ecuadorian population in Minnesota is approximately 18,271, while the Somali population is around 64,354.
Somali Population by State 2026 — World Population Review
Violence in Ecuador, driven by powerful drug gangs with links to cartels in Mexico and Europe, has led to an explosion of violence, prompting hundreds of thousands to flee since 2020.
Why Ecuador Invited the U.S. Military to Help With Its Drug Gangs — The New York Times
📰 Source Timeline (2)
Follow how coverage of this story developed over time
- Names and describes the specific internal document at issue, the 'Home Entry Memo' titled 'Utilizing Form I‑205, Warrant of Removal,' allegedly used to train agents.
- Details whistleblower allegations that ICE instructors were shown the memo 'in secret,' told not to take notes, and that it was primarily used to train inexperienced recruits.
- Describes in greater detail the plaintiffs’ experiences: forced entries into homes, including instances where agents allegedly pushed past residents and searched without judicial warrants.
- Clarifies the relief sought: formal vacatur of the Home Entry Memo, a declaration that the practice is unconstitutional, and ongoing injunctive relief to prevent future use.
- Quotes from ACLU of Minnesota and Protect Democracy attorneys framing the policy as a deliberate end‑run around the Fourth Amendment, not a misunderstanding.
- Spells out that the lawsuit is filed in federal court in Washington, D.C., directly targeting DHS headquarters, not just local ICE operations.