Secret ICE memo instructs agents they can forcibly enter homes without judicial warrants
Whistleblowers say agents were warned: speaking out means termination
Acting ICE Director Todd Lyons signed the memo on May 12, 2025, authorizing agents to use Form I-205 — a warrant of removal signed by an ICE supervisor, not a judge — to forcibly enter private homes, overriding longstanding DHS training materials that stated a Form I-205 does not authorize a Fourth Amendment search
Key Concepts
Essential concepts and terms to understand this topic
Consent Searches
Searches conducted by police after obtaining voluntary permission
Fourth Amendment
The constitutional right protecting people from unreasonable government searches and seizures, generally requiring a warrant based on probable cause.
Exigent Circumstances
Emergencies that allow police to conduct searches without warrants.
Search and Seizure
Protection against unreasonable government searches and seizures.
Warrant Requirement
Rule that police need court approval before searching property or seizing evidence.
Judicial Warrant
Court order signed by a judge authorizing law enforcement to arrest, search, or seize evidence.
Digital Privacy
Fourth Amendment protection requiring warrants before police search digital devices containing personal data.
Probable Cause
Reasonable belief that a crime occurred or that evidence will be found in a particular location.
Unreasonable Searches
Searches that violate Fourth Amendment protections against warrantless intrusion into privacy.
Particularity Requirement
Fourth Amendment requirement that warrants must describe exactly what to search and seize.
Third Party Doctrine
Legal doctrine allowing police to access data shared with third parties without a warrant.
Key People
5Todd Lyons
Acting ICE Director who signed the May 12, 2025 memo
Lyons authorized agents to use Form I-205 administrative warrants to forcibly enter homes, overriding longstanding DHS policy and contradicting existing written training materials.
WA
Whistleblower Aid clients
Anonymous ICE agents who filed the disclosure
Two anonymous ICE agents submitted a whistleblower complaint to the U.S. Senate exposing the memo, risking termination under explicit threats from the agency.
Kristi Noem
Secretary of Homeland Security
As DHS Secretary, Noem oversees ICE and the department whose Office of General Counsel provided the legal rationale cited in the Lyons memo.
DO
DHS Office of General Counsel
Executive branch lawyers who authorized the policy
The memo cites a DHS OGC determination that the Constitution, the Immigration and Nationality Act, and immigration regulations do not prohibit using administrative warrants alone to enter homes — a conclusion constitutional scholars dispute.
WA
Whistleblower Aid
Nonprofit legal organization representing the ICE whistleblowers
Whistleblower Aid submitted the disclosure to the U.S. Senate and publicized the memo's existence on January 22, 2026.
What you can do
Demand your senators rescind the Lyons ICE home-entry memo
legislative contact
Acting ICE Director Todd Lyons signed a memo on May 12, 2025, authorizing agents to forcibly enter homes using Form I-205 — an administrative warrant signed by an ICE supervisor, not a judge. The Supreme Court ruled in Payton v. New York (1980) that the government needs a judicial warrant to enter a home. Sen. Richard Blumenthal has already sent a demand letter to DHS Secretary Kristi Noem; your senators can add pressure through committee oversight and a rescission demand.
Support Gibson v. DHS — the ACLU lawsuit challenging the home-entry memo
legal advocacy
On April 2, 2026, the ACLU, ACLU of Minnesota, ACLU of DC, and Protect Democracy filed Gibson v. DHS against ICE's Home Entry Memo. The lawsuit argues the Lyons memo violates the Fourth Amendment and the Administrative Procedure Act. Donating or volunteering supports the legal challenge that could block warrantless home entries for both immigrants and U.S. citizens.
Look up your rights — know how to spot a real judicial warrant at your door
research
ICE agents carrying Form I-205 have been authorized by the Lyons memo to force entry — but courts haven't upheld that authority. A judicial warrant has a judge's signature, a case number, and a court seal; Form I-205 has only an ICE supervisor's signature. The ACLU's Know Your Rights materials explain exactly what to look for and what to say. Sharing these materials with neighbors is a concrete community protection step.
Track the Gibson v. DHS case docket on PACER for court rulings
monitoring
Gibson v. DHS is the live federal lawsuit challenging the Lyons home-entry memo. Court orders in this case could block ICE from using Form I-205 for home entry nationwide. PACER lets any citizen search federal court dockets and download orders without needing a lawyer. Monitoring the docket keeps you informed of injunctions, appeals, and rulings in real time.