A Joe Biden leftover on the federal bench in Los Angeles just made it harder for immigration agents to arrest people who are already in the country illegally.
On Wednesday, U.S. District Judge Maame Ewusi-Mensah Frimpong unsealed a preliminary injunction she signed under seal on September 2, the LA Times reported.
The order blocks ICE and Border Patrol from making civil immigration arrests without a warrant across the Central District of California unless agents first decide, and then write down “specific, particularized facts,” that the target is likely to escape before a warrant can be obtained.
The district covers Los Angeles, Orange, Riverside, San Bernardino, Ventura, Santa Barbara, and San Luis Obispo counties, home to roughly 19 million people and one of the densest illegal-alien populations in the country.
Frimpong, a 2022 Biden appointee with a Harvard degree and a Yale law degree, wrote that the government “is regularly abstaining from conducting a likelihood of escape analysis at all.”
She also declared that “mere presence within the United States in violation of United States immigration law is not, by itself, sufficient” to treat someone as an escape risk.
She denied the Justice Department’s request for a 14-day stay so the government could consider an appeal. The paperwork rules take effect immediately.
Federal law already lets immigration officers make a warrantless civil arrest when they have reason to believe the person is here unlawfully and is likely to escape before a warrant can be secured. That is 8 U.S.C. § 1357(a)(2).
Frimpong is now telling agents that unlawful presence itself does not count, and that they must document a pre-arrest, individualized escape analysis or stand down.
Plaintiffs, the ACLU of Southern California, Public Counsel, and a coalition of immigrant-advocacy shops, told the court that a review of 113 government arrest narratives showed nearly 80 percent either contained no escape-risk assessment or used boilerplate language. The judge bought it.
An ACLU lawyer celebrated that the order “should put an end to hundreds — if not more — of unlawful arrests.”
This is the same judge who last summer tried to shut down “roving” immigration stops in Southern California, claiming agents were relying on race, Spanish, accents, and job type. The Supreme Court stayed that order in September 2025. She is back with a different lever: paperwork on flight risk.
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