How many cases of U.S. citizens mistakenly detained or deported have been documented by federal audits or courts since 2010?
Executive summary
Federal records and audits do confirm that U.S. citizens have been mistakenly targeted by immigration enforcement since 2010, but the only formal federal audit covering recent years (the Government Accountability Office) documents a narrow slice: from fiscal year 2015 through mid‑2020 ICE arrested 674 people identified as potential U.S. citizens, detained 121, and removed (deported) 70 individuals in that period [1]. Courts have adjudicated and settled individual wrongful‑deportation and detention cases — for example Mark Lyttle and Andres Robles — but there is no single, comprehensive court tally since 2010 comparable to the GAO audit [2] [3] [4].
1. GAO’s hard numbers: what a federal audit actually counted
The Government Accountability Office — the federal audit arm of Congress — reviewed ICE and CBP practices and reported that, based on available agency data, ICE issued detainers for at least 895 potential U.S. citizens from FY2015 through the second quarter of FY2020 and that ICE’s data showed 674 arrests, 121 detentions, and 70 removals of people identified as potential U.S. citizens during that same window [1]. Those figures are presented in the GAO’s review of enforcement actions involving citizenship investigations and are the clearest federal audit numbers available in the record provided [1].
2. What courts and lawsuits show: individual confirmed wrongful removals and settlements
Federal courts and civil suits have repeatedly confirmed specific wrongful deportations and detentions: Mark Lyttle, a U.S. citizen, was wrongfully deported in 2008 and his case proceeded through federal court with magistrate recommendations and subsequent litigation documenting his ordeal and legal claims [2], while Andres Robles was deported and later obtained a federal settlement and correction of records and a $350,000 payment after litigation exposed the government’s error [3]. The ACLU and other litigants have publicized additional court actions and settlements reflecting individual, documented cases of wrongful deportation or detention [4] [2].
3. Bigger estimates exist — but they are not federal audits or court tallies
Academic and advocacy reports have produced much higher estimates stretching across earlier decades — for example, some researchers and commentators have cited figures suggesting thousands to tens of thousands of mistaken detentions or deportations in earlier periods (one quoted estimate places over 20,000 between 2003 and 2011) — but those are not the product of a federal audit and rely on disparate sources, FOIA releases, and extrapolations rather than a consolidated federal count [5] [6] [7]. The GAO itself notes limitations in available agency data and the difficulty of producing a complete tally [1].
4. Limits of the official record: why a precise since‑2010 number is elusive
The federal audit covers only FY2015–Q2 2020 and relies on ICE and CBP internal data, which GAO found to be incomplete and inconsistently tracked; GAO therefore recommended improved tracking and procedures for citizenship investigations — meaning the 70 removals figure is authoritative for that audited span but not an exhaustive accounting for all years since 2010 [1]. Similarly, court records document discrete cases and settlements but do not amount to a centralized federal count; combining GAO’s audit with court‑verified cases gives a conservative, verifiable baseline but cannot claim to capture every instance since 2010 [1] [3] [2].
5. Direct answer and context: what can be stated with confidence
Based on federal audit data and documented court cases in the sources provided, the verifiable federal audit figure is 70 confirmed removals (deportations) of people identified as potential U.S. citizens during FY2015 through mid‑2020, with ICE data also showing 674 arrests and 121 detentions in that period [1]; separately, courts have confirmed multiple wrongful deportations and awarded settlements in individual cases such as Andres Robles and Mark Lyttle [3] [2]. There is no single federal audit or consolidated court database in the supplied reporting that produces a definitive total of all citizen wrongful detentions or deportations dating back to 2010, and some scholarly estimates outside federal audits place the historic magnitude much higher though those estimates are not federal audits [5] [7].