For many campus leaders, immigration enforcement still lives in the abstract something governed by federal policy statements, legal guidance, or long-held assumptions about “sensitive locations.” But when ICE shows up on campus, preparedness has very little to do with theory. It has everything to do with whether the institution has already decided who is in charge and how the interaction will be handled.
Recent shifts in federal guidance, paired with persistent misunderstandings about authority, access, and warrants, have widened the gap between what institutions expect and what actually happens. When problems occur, they rarely stem from enforcement activity itself. They come from the absence of clear internal governance no policy, no ownership, no defined response.
That is where most campuses are exposed.
The First Reality Check: “Sensitive Location” Is Not a Shield
Schools, colleges, and universities are designated as sensitive locations under longstanding ICE policy. That designation is often misread as a prohibition. It is not.
Sensitive location guidance establishes discretion, not immunity. Enforcement actions generally require higher levels of approval and are typically avoided, but they are expressly permitted under certain conditions; national security concerns, imminent safety risks, or active pursuit scenarios among them.
The real blind spot is not whether ICE can come to campus. It’s whether the institution has decided who controls the response if they do.
When leaders plan as if enforcement “won’t happen here,” authority defaults to the first person encountered often a receptionist, student worker, or front-line staff member. That is where risk enters the system.
Where Risk Actually Concentrates: Public vs. Private Space
Few issues are more poorly understood, or more operationally consequential, than space classification.
Federal guidance draws a clear distinction between:
- Public areas, open to anyone without restriction
- Private or non-public areas, where access is limited and a reasonable expectation of privacy exists
ICE officers may enter public areas without a warrant and may question individuals present. Entry into private areas requires either valid consent from an authorized institutional representative or a judicial warrant, not an administrative one.
The problem is that many campuses never operationalize this distinction. They fail to define, in real terms, which spaces are public, which are private, and critically who is authorized to make that determination in the moment.
Lobbies, reception areas, student service desks, and mixed-use spaces often sit in a gray zone. When policy is unclear, control quietly shifts away from the institution and toward the requesting party.
“Without a policy that clearly establishes authority, access decisions are made ad hoc, often under pressure.” — Paul Sarnese
Administrative vs. Judicial Warrants: A High-Stakes Distinction
Warrant recognition is another common failure point.
ICE administrative warrants are issued internally by the agency and are not signed by a judge. They do not authorize entry into private areas without consent. Judicial warrants, by contrast, are court-issued, signed by a judge or magistrate, and specify time, location, and scope.
In real-world campus scenarios, breakdowns rarely occur because a warrant existed. They occur because no internal policy defined who could review it, how it should be validated, or how staff should respond.
A document labeled “warrant” does not resolve the question of access. The obligation to verify, escalate, and decide belongs to the institution—not the agency presenting it.
Preparedness Is a Governance Problem, Not a Security One
Campus practitioners are increasingly clear on this point: ICE preparedness is not about physical security measures. It is about governance discipline.
Prepared institutions do three things consistently:
- Establish a formal policy defining how ICE interactions are handled
- Designate a small, trained group authorized to interface with ICE
- Train all first points of contact reception, student services, facilities, security to immediately route interactions without answering questions or granting access
They also rehearse. Tabletop exercises that include legal, compliance, executive leadership, and communications teams are standard practice where readiness is taken seriously.
Where institutions fall short is assuming, the existence of a policy is enough. It isn’t. Policy only works when staff know it exists and understand their role within it. Without that clarity, well-intentioned employees may inadvertently consent to access, disclose information in plain view, or escalate a situation by trying to be helpful.
The Tradeoff Leaders Rarely Name
Every campus response to ICE presence involves an unavoidable tension:
- Operational continuity versus reputational impact
- Legal compliance versus community trust
Ignoring that tension doesn’t eliminate it. It simply pushes the decision onto the least prepared person at the most pressured moment.
Prepared campuses confront this tradeoff in advance. They establish decision logic that prioritizes legal compliance, safety, and controlled, consistent communication. This is not about advocacy or resistance. It is about institutional control ensuring values are upheld through process rather than improvisation.
What Leaders Should Take Away
The most dangerous assumption campus leaders make is that ICE preparedness belongs to someone else legal, security, or administration.
In practice:
- Risk concentrates at first contact
- Confusion creates exposure
- Silence is often safer than speculation
- Policy determines who controls the interaction, not the presence of enforcement
Institutions that treat ICE encounters as low-frequency, high-impact operational events and that define in advance who speaks, who decides, and who grants access are far better positioned to protect students, staff, and the institution itself.
Preparedness does not prevent enforcement. It prevents the loss of control when enforcement occurs.
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We appreciate Julia Ann Easley for sharing this comprehensive UC Davis resource addressing federal immigration enforcement policies, resources, and guidance.
A big thank-you to our guest author for contributing to this article. Interested in learning more? You can schedule time with them here: Book time with Paul Sarnese
