At a Glance
- ICE agents have shot and killed 25 people since 2015 without a single criminal indictment
- Agent Jonathan Ross shot Renee Nicole Good on January 7, 2026, in Minneapolis
- Federal and state agencies routinely clear agents, citing self-defense and qualified immunity
- Why it matters: Victims’ families have almost no legal recourse, and disciplinary records stay secret
When Jonathan Ross fired multiple rounds at Renee Nicole Good last Wednesday in Minneapolis, the 37-year-old mother became the 25th person known to have been killed by an Immigration and Customs Enforcement agent since 2015. Not one of those shootings has led to criminal charges against an agent.
A four-year review of ICE logs, court filings, and more than 40 interviews found a pattern of internal clearances, opaque federal investigations, and legal doctrines that shield agents from both civil lawsuits and state prosecutions.
Shooting Patterns
ICE logs obtained through a two-year lawsuit show that, before the Good killing:
- Agents opened fire in moving-vehicle situations 19 times, causing 10 deaths and 6 injuries
- Bystanders were present in 22 incidents
- The person shot was not the enforcement target in 7 cases
- Three reports list a suspect’s “hands/feet/body” as a weapon
- At least 12 victims appear to have been unarmed
The Self-Defense Standard
ICE spokesperson Mike Alvarez said in 2024 that deadly force is allowed when “objectively reasonable and necessary.” Former federal agent Mike German told News Of Fort Worth that prosecutors usually accept an agent’s “subjective belief” that life was in danger, making indictments rare.
Qualified immunity, reinforced by Supreme Court rulings in Mesa v. Hernandez (2020) and Egbert v. Boule (2022), blocks most civil suits against federal officers. German added that investigations “very rarely find the agent in violation of law or policy.”
Jurisdiction Gaps
State and federal authorities can investigate simultaneously, but turf battles often leave the FBI as the sole agency. In the 2018 Dumfries, Virginia, killing of an unarmed man, the commonwealth’s attorney halted its probe, citing lack of jurisdiction over federal agents, and transferred files to the FBI, which never disclosed its findings.
A similar pattern unfolded in Nashville in September 2019. Video showed an ICE agent shooting at a truck as it pulled away from a grocery store; the FBI never released the results of its inquiry.
Good Investigation Stalled
One day after Ross shot Good, Minnesota’s Bureau of Criminal Apprehension “reluctantly” stepped aside when the U.S. Attorney’s Office said the FBI would handle the case alone and barred state access to evidence. The move does not stop Minnesota Attorney General Keith Ellison or Hennepin County Attorney Mary Moriarty from launching separate homicide probes. Moriarty has received “hundreds of calls and emails” demanding an independent investigation but so far says only that her office “stands ready” to assist the FBI.
Governor Tim Walz urged residents to film ICE activity: “Help us create a database of the atrocities against Minnesotans … to bank evidence for future prosecution.”
Internal Discipline Rare
ICE’s Office of Professional Responsibility reviews every shooting but cannot impose discipline; recommendations go to the agent’s supervisor, who can accept or reject them. Appeals can drag final action out for years.
A 2023 Government Accountability Office report found that ICE often logged use-of-force incidents without documenting whether they violated policy. Author Gretta Goodwin said she saw reprimands and suspensions but no data on firings.
ICE adopted a new firearms policy in 2023 following a White House order on police reform, but released only a heavily redacted version. The agency declined to provide an unredacted copy or confirm how many people its agents have shot.
Political Rhetoric
Homeland Security Secretary Kristi Noem labeled Good’s death a response to “domestic terrorism.” J. Wells Dixon of the Center for Constitutional Rights called the claim “baseless,” adding, “Secretary Noem obviously lied … to suggest-falsely-that she somehow deserved to be murdered by a masked ICE agent.”

Vice President JD Vance asserted on January 8 that ICE agents have “absolute immunity,” a term with no established legal meaning. President Trump has reportedly instructed officials to shield agents, including 12,000 new recruits, from prosecution.
Key Takeaways
- No ICE agent has ever faced criminal charges for an on-duty shooting
- State and federal agencies frequently defer to each other, leaving cases with the FBI, which rarely discloses outcomes
- Qualified immunity and recent Supreme Court decisions block most civil rights lawsuits
- Internal ICE reviews can recommend discipline, but supervisors decide whether to act, and outcomes are secret
Cameron R. Hayes is an independent investigative multimedia journalist based in New York City.

