Have courts elsewhere ruled on ICE's use of administrative warrants or knock‑and‑talk tactics in other jurisdictions?

1. Lower courts have pushed back: a growing body of adverse rulings

Multiple lower federal courts have concluded that ICE agents who forcibly entered homes relying only on administrative warrants violated the Fourth Amendment when no recognized exception applied, and Congress’s and courts’ descriptions of administrative warrants as non‑judicial have informed those holdings ^{[1] [2]}. Reports and summaries by legal organizations document that administrative immigration warrants are issued by ICE or immigration judges in the immigration-court context and do not carry the same judicial imprimatur as a magistrate‑signed criminal warrant, which has factored into adverse rulings ^{[4] [2]}.

2. Notable judicial remedies and context: injunctions and limited rulings

Some courts have gone beyond factual findings to issue injunctions or preliminary relief in specific contexts—most prominently requiring DHS to honor prior “protected areas” policies for places of worship except where enforcement is pursued via a judicial or administrative warrant—illustrating that courts will tailor relief where constitutional or statutory claims are likely to succeed ^[1]. Reporting by major outlets also shows litigation erupting after agency memos that appear to broaden reliance on administrative warrants, with advocacy groups urging courts to step in as executions of those memos increase ^{[5] [6]}.

3. The Supreme Court has not definitively settled the question

Supreme Court jurisprudence contains references suggesting long‑standing administrative arrest practices, but the Court has repeatedly declined to rule directly on whether administrative warrants satisfy the Fourth Amendment’s warrant requirement—most famously in decisions where the Court refused to consider such challenges because the arguments were not preserved below—leaving a doctrinal gap that lower courts have filled unevenly ^[3]. Legal analysts and commentators note that the high court’s silence has allowed divergent outcomes across jurisdictions ^[3].

4. ICE’s and training materials’ interpretation versus civil‑liberties groups

ICE training and agency materials affirm the routine use of administrative removal warrants and instruct officers on their scope and limits—training that emphasizes administrative arrest authority but also recognizes restrictions such as “REP” (reasonable expectation of privacy) areas where entry without judicial authority is contested—while ICE public guidance stresses that it generally does not need judicial warrants to make arrests ^{[7] [8]}. Civil‑liberties groups, public‑interest law centers, and legal aid organizations respond that administrative warrants do not authorize entry into homes or private non‑public business areas without a judicial warrant or consent, and they uniformly advise refusing entry absent a judge‑signed warrant ^{[9] [10] [11]}.

5. The practical takeaway: jurisdictional patchwork and ongoing disputes

The practical landscape is a patchwork: lower courts have ruled both for and against ICE practices depending on affidavits, factual context, and whether defendants challenged administrative warrants at the right procedural moment, and courts have sometimes limited enforcement in sensitive locations like houses of worship ^{[1] [4]}. Because the Supreme Court has not definitively ruled, and because agency memos and training continue to evolve, litigation and policy disputes over administrative warrants and knock‑and‑talk entries will continue to produce jurisdiction‑specific rulings rather than a single nationwide rule ^{[3] [5]}.