In the event of an unannounced visit to George Washington University’s campus by immigration enforcement officials (“Agents”), university offices should follow this guidance. If it is not clear whether the purpose of the unannounced visit is immigration-related, university offices may still follow this guidance.
This guidance is intended to describe the process to follow if Agents arrive unannounced on campus, so that the university may evaluate the situation in accordance with its policies and procedures. It is not intended as individual legal advice or to create a legal right in others to have the university follow this guidance.
Included with this guidance are checklists to assist university offices in the event of such a visit.
Each university office should be aware of this guidance and know to contact GWPD and OGC if Agents arrive unannounced. For questions about this guidance or about unannounced visits to campus by Agents for other purposes, contact the Office of the Senior Vice President and General Counsel (OGC) at (202) 994-6503 or [email protected].
See below for checklist guidance.
The Department of Homeland Security’s Immigration and Customs Enforcement division (ICE) carries out immigration-related enforcement actions such as arrests, interviews, searches and surveillance. ICE considers universities to be “sensitive locations.” This means that ICE Agents are ordinarily directed not to undertake immigration-related enforcement actions at schools, where possible. This is not a blanket prohibition on lawful enforcement operations: ICE may carry out certain immigration enforcement actions even at sensitive locations and the university is not considered a sensitive location for other law enforcement purposes.
In most cases, Agents may not immediately go beyond GW public spaces into a university premises, such as individual offices, labs, conference rooms, residence halls and classrooms. A GW public space may be outside, or inside, such as a lobby or entryway to a building that does not require special access.
If Agents attempt to enter non-public spaces, state, “I am not authorized to let you enter. I will call our university police department now so they may speak with you.”If any Agent forces his/her way in, call the George Washington Police Department (GWPD) immediately and alert your supervisor. Under no circumstances should you attempt to physically obstruct Agents’ activities.
University police will not participate in joint enforcement actions against individuals based solely on immigration status, unless required by law.
Agents must have a warrant to seize university property or documents, or to take individuals into custody. Despite having a warrant, unless certain circumstances exist, Agents should not begin carrying out the warrant until GWPD and/or OGC has reviewed it.
If the Agents attempt to carry out the warrant, state, “Please wait while I contact our university police department.” If they do not wait, alert GWPD right away.
A university office may wish to identify a conference room or other space, near where the Agents enter, where discussions (as instructed by GWPD and/or OGC) can be held in a confidential manner.
- Subpoenas and Other Legal Notices
- Requests for Student Records
- Attorney Client Privilege
- Retaining Outside Counsel
- Advisory on Political Activities
- Calls, Visits, and Letters from Attorneys, Law Enforcement Officials, or Regulatory Agency Investigators
- Personal Representation and Personal Liability
- Signature Authority
- Unannounced Visits by Government Agents for Immigration Related Enforcement Actions
Office of the Senior Vice President and General Counsel
2100 Pennsylvania Avenue, NW Suite 250
Washington, DC 20052