FAQs Regarding Immigration Enforcement Actions

This FAQ provides guidance to the university community in the event U.S. Immigration and Customs Enforcement (ICE) agents arrive on campus as part of an immigration law enforcement action.

It is important to remember that agents from the Department of Homeland Security (DHS), which includes ICE, or other federal agencies, may be on campus for a variety of reasons. We caution against assuming that a law enforcement employee is visiting campus as part of an enforcement action.

Are university campuses still defined as “sensitive” or “protected” locations where ICE enforcement actions are limited?

No. On January 21, 2025, the Acting Secretary of DHS announced the rescission of prior ICE guidance on “sensitive” or “protected” locations. Since 2011, ICE operated under an internal guidance memoranda that prohibited ICE agents from engaging in enforcement actions (arrests, interviews, searches, or surveillance) at “sensitive locations” such as colleges and universities, with limited exceptions. That internal ICE guidance is no longer in place.

What should COMMUNITY MEMBERS do if they observe ICE agents/officers on campus?

• Agents from DHS, which includes ICE, or other federal agencies, may appear on campus for a variety of reasons. As noted above, ICE may come to campus for reasons related to regulations that do not involve alleged immigration violations.
• If you encounter ICE or other federal law enforcement agents on campus and are concerned about their activities, you should immediately contact Campus Safety dispatch at 503-370-6911 for the Salem campus and at 503-621-2061 for the Portland campus.

Does ICE need a warrant to access WU’s campus?

• All campus buildings are access controlled unless a scheduled public event is taking place in that building or it is designated as open to the public during business hours. Areas open to the general public may be entered without a warrant. These public spaces include Goudy Commons during meal hours, Putnam University Center, University Services, Wish, and Hatfield Library. All other campus buildings (i.e., academic buildings, Schnitzer Center for Art and Design, Sparks Athletic Center, residence halls and campus apartments, Montag Hall, and Waller Hall) are private spaces.
• ICE agents must have a judicial search or arrest warrant signed by a judge of a federal or state court (as opposed to an administrative warrant) to access nonpublic areas of campus.

What should a COMMUNITY MEMBER do if agents ask to enter non-public areas of a university building?

• Community members should be polite and ask agents to wait while they contact Campus Safety dispatch at 503-370-6911 for the Salem campus and at 503-621-2061 for the Portland campus. See these Sample Talking Points for encounters with federal law enforcement personnel. 
• Campus Safety will come to meet with the agents, and will also attempt to contact the university’s General Counsel or other senior administrative leader for assistance.
• Under no circumstances should you attempt to physically obstruct a law enforcement agent’s activity. Instead, immediately contact Campus Safety
• Campus Safety and/or the General Counsel, or another senior administrative leader, will review any warrant or subpoena carefully.

What should employees do if a law enforcement agency contacts them and asks for information about a student or a student’s education record?

• An employee who receives an in-person request from law enforcement for information about a student (including “directory information” as defined in WU’s FERPA Policy) or for access to university records or property, should immediately contact Campus Safety dispatch at 503-370- 6911 for the Salem campus and at 503-621-2061 for the Portland campus. Campus Safety will contact the university's General Counsel or other senior administrative leader for assistance.
• The employee may wish to say, “I am not authorized to disclose student data because of the university’s legal confidentiality obligations under FERPA. Your request needs to be directed to the General Counsel.”
• Employees who receive a subpoena of any kind, whether it is from a government agency or third-party, or other written request for student information, should immediately direct the subpoena to the Office of General Counsel by calling 503-370-6825 and emailing the subpoena to general-counsel@willamette.edu. The General Counsel will determine the university’s obligations regarding the subpoena and respond accordingly. In doing so, the university will comply with the Family Education Rights and Privacy Act (FERPA).
• FERPA generally prohibits schools from disclosing personally identifiable information from a student’s education records, with certain exceptions. The most important exception to FERPA’s general rule prohibiting disclosure of a student’s education records is when disclosure is done pursuant to a lawfully issued subpoena. Again, it is up to the General Counsel to determine the university’s legal obligations pursuant to a subpoena.

What should I do if somebody asks me for help regarding an immigration-related issue?

Although the university cannot give legal advice, you can provide this link to community members: Resources.