Ballard Spahr Posts Document on Preparing for Ice Visits
On January 29, 2025, the law firm Ballard Spahr posted a document titled “Preparing for ICE Visits in Light of Executive Orders.” The document notes that the administration revoked a policy that “restricted federal immigration authorities from carrying out enforcement activities at sensitive locations including schools, churches, and hospitals.” The document provides context around employers’ rights and responsibilities if ICE agents visit.
The document discusses the different types of immigration visits and discusses rights of access. It notes the difference between I-9 audits, site visits, and immigration raids. In discussing rights of access, it distinguishes between public areas and private areas. It also discusses the differences between judicial warrants and administrative warrants.
Finally, the document provides action steps. One section notes steps organizations should take before ICE arrives. These steps include designating nonpublic areas; designating a point of contact; training staff at points of entry; evaluating I-9 compliance; and reviewing and organizing visa status documentation for sponsored employees. Another section notes steps for organizations to take when ICE arrives. These steps include reviewing any ICE documents; document interactions (i.e., documenting pertinent information and collection agent names and badge numbers); being calm, composed, and cooperative; and potentially reaching out to counsel.
The full document can be found here.