New York Judge Rules ICE Detention at LaGuardia Illegal

(NEW YORK) A federal judge in Manhattan has ruled that U.S. Immigration and Customs Enforcement illegally detained a lawful permanent resident at LaGuardia Airport just days before Thanksgiving 2025, in a decision that immigrant advocates say could reshape how the agency conducts airport arrests in New York and beyond. On November 26, 2025, U.S. District Judge Analisa Torres of the Southern District of New York held that ICE’s actions violated the Fourth Amendment and a long‑standing federal settlement that limits warrantless immigration arrests in the state.

Case background and timeline

• The case, Jane Doe v. U.S. Immigration and Customs Enforcement, centers on a woman identified only as Jane Doe, a green card holder who returned to the United States through LaGuardia Airport on November 21, 2025, after a trip abroad.
• While passing through routine customs checks, ICE officers intercepted her, claimed she might be removable based on an old criminal conviction, and took her into custody without a judicial warrant.
• She was held in immigration detention in the days leading up to the holiday.

Key dates and data

Ruling: constitutional and settlement grounds

Judge Torres found that ICE agents did not have probable cause at the time of the arrest to believe Doe was removable under immigration law. The court held that the government failed to meet the Fourth Amendment requirement that arrests be supported by a concrete, individualized reason, not just a vague suspicion or a computer alert.

The ruling also relied on the 1997 Humboldt settlement, a federal court agreement that restricts ICE’s ability to make civil immigration arrests in New York without probable cause. Judge Torres concluded that by detaining Doe at LaGuardia based mainly on a database flag and an old conviction record, ICE violated both:

• the U.S. Constitution (Fourth Amendment), and
• the Humboldt settlement.

She ordered Doe’s immediate release and barred the agency from using similar tactics against her in the future without proper legal grounds.

“ICE cannot treat airports as ‘law‑free zones’ where agents can detain lawful permanent residents and other noncitizens simply because they are returning from abroad,” Judge Torres wrote, stressing that the Fourth Amendment follows people through airport arrivals just as it does on a city sidewalk or in a family home.

What the court said about evidence and probable cause

• The court emphasized that an immigration database flag or an old conviction record alone is insufficient to justify a warrantless arrest.
• ICE must have up‑to‑date information and a concrete legal theory showing the individual was removable at that precise moment.
• Old records, standing alone, do not meet the Fourth Amendment’s probable‑cause standard.

Context: rise in airport enforcement

According to reporting cited in the case, Documented NY found in early December 2025 that ICE arrests at U.S. airports spiked by 94% compared with the same period in 2024. Major hubs, including LaGuardia, have seen especially steep increases, with more people pulled aside after landing and taken into immigration custody on the basis of old or questionable information.

Advocates say Doe’s experience reflects that broader trend: ICE has been leaning heavily on automated flags in immigration databases, sometimes based on decades‑old convictions that may no longer render a person removable or may have been addressed in prior immigration proceedings.

Broader legal ripple effects

• Lawyers in pending cases in Chicago and Washington, D.C. have cited Judge Torres’ opinion as support for claims that ICE has adopted a pattern of warrantless arrests and aggressive use of expedited removal.
• Because the opinion ties ICE’s airport conduct to both the Fourth Amendment and a specific settlement (Humboldt), analysts (e.g., VisaVerge.com) say the decision has extra force.
• The ruling not only constrains future arrests in New York but also provides a model lawyers in other states may try to apply when challenging similar airport operations.

Government position and the court’s response

• The government argued that the combination of Doe’s prior conviction and a database hit gave ICE enough basis to act quickly at LaGuardia.
• Judge Torres rejected that position, requiring the agency to show it had fresh, individualized probable cause that the person was removable at the moment of arrest.
• This interpretation raises the evidentiary bar for front‑line officers who may have treated database alerts as sufficient grounds for detention.

Implications for lawful permanent residents and travelers

• For green card holders, the decision carries special weight: returning residents already face anxiety at inspection lines, particularly if they have any past contact with the criminal system.
• Torres’ opinion reinforces that even in airport terminals—where federal agents can ask questions and review documents—agents must respect Fourth Amendment protections before turning an inspection into an arrest.

Practical takeaways for travelers:
– Consider reviewing your immigration history with qualified legal help before leaving the country if you have past convictions.
– Be aware that someone stopped at inspection may not know whether officers have the level of probable cause described by Judge Torres.
– ICE still retains authority to question travelers, check records, and make arrests when they have solid probable cause.

Important: This ruling does not erase ICE’s authority at airports; it clarifies the legal standards ICE must meet in New York (and sets persuasive precedent elsewhere).

Additional resources

More information on ICE’s detention and arrest authority is available from U.S. Immigration and Customs Enforcement, which outlines the agency’s role and the legal framework that applies to civil immigration enforcement.

Conclusion

For Jane Doe, the order for her release marks the end of one sudden and frightening turn in what was supposed to be a routine holiday return through LaGuardia Airport. For ICE, the ruling stands as a warning that even during a surge in enforcement, federal judges are watching closely to see whether the government respects the constitutional limits on its power to arrest. 🇺🇸