Denver Federal Court Finds ICE in 'Manifest Noncompliance' with Colorado Warrantless Arrest Injunction — Orders 45-Day Mandatory Training for All Officers

U.S. District Judge R. Brooke Jackson (D. Colo.) issued a comprehensive order on May 12–13, 2026, finding ICE in 'manifest noncompliance' with a November 2025 preliminary injunction that barred Colorado ICE officers from making warrantless civil immigration arrests without documenting particularized facts supporting a reasonable basis to believe the target was subject to removal. The case, brought by the ACLU of Colorado, centered on the warrantless arrest of Caroline Dias Goncalves, 20, a University of Utah nursing student who had arrived in the U.S. at age 7. She was stopped at a traffic stop near Loma, Colorado, arrested without a judicial warrant, and held for 15 days at Aurora's Northwest ICE Processing Center. The court reviewed 36 I-213 immigration arrest records produced by ICE and found that none of them complied with the November injunction's documentation requirements. ICE officers testified they did not understand the lawful protocols, had not received training on the court's requirements, and in multiple cases appeared to deliberately circumvent the injunction's terms. The court ordered: (1) mandatory compliance training for all ICE officers authorized to make warrantless civil arrests in Colorado within 45 days; (2) implementation of new internal reporting procedures; and (3) submission of documented particularized flight-risk facts for each warrantless arrest going forward. Colorado Senator John Hickenlooper called the ruling 'a major rebuke to ICE over unlawful arrests in the state.' The ruling adds to a pattern of federal courts finding ICE noncompliance with judicial orders — including the March 31, 2026 deportation to El Salvador's CECOT despite an active TRO — as the Trump administration continues its record-pace enforcement campaign.