How many ICE agents have been sued for 4th amendment violations since 2020?

1. What the submitted materials actually claim — lawsuits, not a headcount

The documents repeatedly assert that ICE has been sued for Fourth Amendment practices, especially over immigration detainers and wrongful detention, but they do not enumerate how many individual agents were named or sued since 2020. The Gonzalez class action and related decisions focus on institutional practices and injunctive relief rather than producing a roster of defendants. The materials reference individual filings—such as the Enriquez-Perdomo matter—that name ICE agents, yet the authors of these analyses explicitly note the absence of any comprehensive figure or database in the sources provided ^{[1] [4] [5]}.

2. Court rulings show ICE detainers and detentions have constitutional problems

Federal appellate rulings and settlements documented here establish that ICE detainer procedures have repeatedly been found deficient under the Fourth Amendment because of lack of probable cause review and neutral decisionmaking, creating fertile ground for litigation. Gonzalez v. ICE and subsequent class action outcomes forced changes to ICE’s detainer practices and limited detainer issuance in certain regions, demonstrating courts’ willingness to enjoin agency procedures rather than merely dismiss claims ^{[1] [2] [3]}. Those rulings increase scrutiny on ICE behavior and invite private litigation even when the number of named agents remains uncounted.

3. Notable individual suits illustrate legal and remedial limits

The Enriquez-Perdomo litigation demonstrates how plaintiffs have sued ICE agents alleging warrantless detentions and Fourth Amendment violations; the courts, however, have grappled with the appropriate remedy. A recent decision held that the claim presented a new Bivens context and declined to extend Bivens because alternative statutory or equitable remedies were available, illustrating that damages claims against federal agents encounter doctrinal barriers even where detention facts are contested. This indicates that plaintiffs can and do sue individual agents, yet obtaining damages against them remains legally challenging ^[5].

4. Why you cannot infer a numeric total from these materials

The supplied analyses repeatedly emphasize the absence of a consolidated count: sources describe class actions, systemic injunctions, and individual suits but none compile post-2020 litigation metrics. Class settlements like Gonzalez resolve claims against the agency and change practices without necessarily identifying or producing a tally of named agent defendants. Individual case summaries mention defendants in context but do not create comprehensive listings. Thus, the materials support the qualitative claim that ICE agents have been sued for Fourth Amendment violations since 2020, but they do not supply the quantitative answer the original question seeks ^{[5] [2] [6]}.

5. How recent settlements and doctrinal rulings change the litigation landscape

Settlements and injunctions forcing ICE to adopt neutral probable-cause reviews for detainers reduce future occurrences of the specific detainer-based Fourth Amendment claims while also shaping plaintiffs’ strategic choices. When courts decline to extend Bivens in immigration-enforcement contexts, that pushes litigants toward statutory, administrative, or habeas avenues and may reduce the number of civil damages suits against individual agents even as systemic litigation continues. The materials show both increased institutional accountability through injunctive relief and constrained avenues for individual officer liability claims ^{[2] [5] [3]}.

6. Bottom line: what is established and what would be needed to answer your question

From these sources, it is established that numerous lawsuits—both class actions and individual suits—alleging Fourth Amendment violations by ICE or ICE agents have proceeded since 2020, and courts have both checked ICE detainer practices and limited Bivens remedies. The materials do not provide a numeric count of ICE agents sued; producing such a number would require systematic litigation database queries, FOIA requests for DOJ or DHS litigation records, or a collation of complaints filed in federal courts post-2020. For a precise tally, compile docket searches for terms like “ICE,” “Fourth Amendment,” and named agent defendants across federal district courts and appeals records ^{[1] [2] [3]}.