DHS and ICE officials didn’t publicize or broadly distribute the legal decision, predicting that it would invite legal scrutiny, the people familiar with the matter said. Last summer, soon after the memo was issued, they launched a pilot program to try it out in Minnesota—for reasons unrelated to the current ICE surge there, the people said.
Immigration lawyers and advocates in Minnesota have documented cases of agents breaking down people’s doors to arrest them without a warrant. The most prominent of those cases concerned a Minnesota man born in Liberia, Garrison Gibson, whose Fourth Amendment right was violated by ICE officers when they broke down his door without his consent and without a judicial warrant, according to U.S. District Judge Jeffrey Bryan.
Gibson was issued deportation orders in 2009 but was allowed to remain in the U.S. under ICE supervision, including wearing an ankle monitor and regularly checking in with immigration officials. His most recent check-in with ICE was Dec. 29, 2025, according to court documents.
On Jan. 11, immigration officers forced their way into Gibson’s home and took him into custody. They told his wife that they had a warrant but didn’t produce a judicial warrant, according to the documents.
Gibson came to the U.S. when he was 6, according to his lawyer, Marc Prokosch. In Judge Bryan’s judgment ordering his release, he wrote that Gibson doesn’t have a criminal record and claimed he wasn’t told why he was arrested. The judge found the detention unlawful in part because of the lack of a judicial warrant.