We also discussed a recent preliminary injunction from a federal court in California concerning warrantless immigration arrests. The court ruled that, within the Central District of California, federal immigration officers may not make a warrantless civil immigration arrest without first making an individualized determination that there is probable cause to believe the person is likely to escape before a warrant can be obtained. Officers must document the facts supporting that determination.

Both cases concern important limits and procedures governing immigration enforcement, but neither decision should be understood as ending deportations or immigration arrests generally.