ICE Records Obtained by American Oversight Corroborate Whistleblower Testimony on Training for Entering Homes Without Warrants

American Oversight recently obtained U.S. Immigration and Customs Enforcement (ICE) records showing that despite formal legal training materials instructing officers that they generally cannot enter a residence without a judicial warrant or consent, instructors were directed to tell cadets that the use of controversial administrative warrants to enter a home were “under review.”

The documents align with sworn testimony from former ICE attorney-turned-whistleblower Ryan Schwank, who told Congress on Monday that he was instructed to train cadets using guidance from Acting ICE Director Todd Lyons’ memo that “claimed ICE officers could enter homes without a judicial warrant” — guidance he was told to read in his supervisor’s presence but not to document. 

Schwank noted that Lyons’ memo “authorized the very conduct that DHS in its own 2025 legal training materials had called the ‘chief evil against which the wording of the Fourth Amendment is directed’ — that is physical entry of the home without consent or a proper warrant.” These legal training materials were among the records we obtained.

“Our basic constitutional rights are threatened if federal law enforcement agencies tell their officers to follow unlawful guidance and to keep it secret,” said Chioma Chukwu, Executive Director of American Oversight. “These records bolster the whistleblower’s claims and suggest a troubling disconnect between ICE’s formal legal training and the way ICE officers were instructed to enter homes without warrants. It is deeply concerning that ICE appears to have ignored clear constitutional limits. That perception alone does lasting damage to ICE’s credibility and erodes public trust in the agency’s commitment to the rule of law and constitutional protections.”

The records, obtained through a Freedom of Information Act lawsuit, include ICE’s “Fourth Amendment Refresher Training (Revised July 2025)” and accompanying instructor notes. The slide materials emphasize that administrative warrants such as a Form I-200 “[do] not authorize entry into a residence” and that a judicial arrest warrant is generally required to enter a home. The training also warns that Fourth Amendment violations can result in suppression of evidence, termination of proceedings, civil liability, and discipline.

Yet the instructor notes accompanying the training presentation state that if trainees specifically asked about the use of Form I-205 administrative warrants for home entry, instructors should advise that the issue was “under review.” The juxtaposition of those materials mirrors Schwank’s testimony that he was instructed to train agents under internal guidance offering expansive warrantless home-entry authority, while being told not to formally document that direction.