4th Circuit affirms limits on warrantless ICE raids at churches

In a unanimous decision, the 4th U.S. Circuit Court of Appeals affirmed a preliminary injunction issued by Judge Theodore D. Chuang that restricts ICE from making warrantless arrests at churches affiliated with a coalition of religious groups. The court concluded that the 2025 immigration policy, rolled out at the start of President Donald Trump’s second term, likely violates the Religious Freedom Restoration Act by suppressing worship attendance and participation in immigrant-focused ministries.

Plaintiffs, including Quaker organizations, Sikh Temple Sacramento, and the Cooperative Baptist Fellowship, presented evidence of attendance drops, such as a 66% decline in ESL class participation at one Baptist congregation. Senior Judge Barbara Milano Keenan highlighted the irreparable injury to religious exercise, while Judge G. Steven Agee noted the Department of Homeland Security’s failure to justify the policy. The injunction is narrowly limited to the identified places of worship; arrests supported by warrants or emergency actions remain allowed. The ruling contrasts with a separate D.C. case where Judge Dabney Friedrich denied a similar injunction.