Immigration Enforcement Activities on Campus Procedure – 61.26.01
1. Howard Community College does not consent to the conduct of civil immigration enforcement operations on the premises.
2. Howard Community College does not authorize any person seeking to enforce immigration laws to enter private spaces, except pursuant to a judicial warrant or where exigent circumstances require such access.
3. The General Counsel shall be the primary point of contact for issues related to immigration enforcement.
4. If U.S. Immigration and Customs Enforcement (“ICE”) agents or other federal immigration authorities appear at Howard Community College, employees shall presume that they are engaged in immigration enforcement. Employees shall proceed as follows:
a. Contact the Office of General Counsel immediately.
b. Ask the federal immigration authorities to wait in a lobby or other public space. If the federal immigration authorities demand immediate access to private spaces without waiting for the General Counsel, employees shall state they do not consent to such access but should not attempt to stop or impede the officer.
c. As promptly as possible, employees shall contact the Office of General Counsel, and make a record of the incident for the General Counsel, including notes about the verbal exchange with the federal immigration authorities, identifying details about the federal immigration authorities, the federal immigration authorities’ actions, any arrests or other results of those actions, and the identity of other employees that witnessed the incident.
In no circumstances should employees interfere with federal immigration authorities, attempt to make them leave a public space, attempt to conceal any person from federal immigration authorities, or attempt to assist any person in evading federal immigration authorities.
5. The Office of General Counsel shall make and maintain records of all immigration enforcement activities at Howard Community College.
6. The Office of General Counsel shall request and record the following information from all federal immigration authorities or other federal officials who appear at Howard Community College on immigration business:
a. Name;
b. Badge number or other official identifying information;
c. Agency;
d. Purpose of visit; and
e. Proposed action to be taken at the college.
7. If an immigration officer requests access to private spaces within Howard Community College to conduct enforcement action, the General Counsel may authorize such access only if the immigration officer (1) asserts that exigent circumstances exist; or (2) possesses a valid judicial warrant. To confirm the existence of a valid judicial warrant, the General Counsel shall:
a. Obtain a copy of the document;
b. Confirm that the heading shows the document was issued by a court;
c. Confirm that a U.S. District Court Judge or Magistrate signed the document;
d. Confirm that it lists Howard Community College among the places to be searched for wanted person or evidence; and
e. Verify that the document is not expired.
8. Employees must ask to consult with the General Counsel about any questions concerning a judicial warrant or the existence of exigent circumstances. If immigration officers deny the employee the opportunity to consult with the General Counsel about such questions, the employee must state that the employee does not consent to the federal immigration authorities’ entry but should not block or impede their access.
9. If immigration officers proceed into a private space without exigent circumstances or a judicial warrant, employees must notify the General Counsel, state that the federal immigration authorities or other federal official lack permission, but make no effort to resist or block the officers.
Requests by Immigration Officers for Records or Information
- The confidentiality of information about employees and students is protected by federal and state laws. Requests made by immigration officers for records or information about students must be forwarded to the Records, Registration & Veterans’ Affairs Office, and the Office of General Counsel. Requests made by immigration officers for records or information about employees must be forwarded to Human Resources and the Office of General Counsel.
- The Office of General Counsel shall obtain a copy of any documentation supporting the immigration officer’s request, such as an administrative subpoena, judicial subpoena, or court order.
- If immigration officers proceed to search a private space without exigent circumstances or a judicial warrant, employees shall audibly state that the officers lack permission, but make no effort to resist or block the officers. Employees must promptly notify the Office of General Counsel of the unauthorized search of a private space.
Effective Date: 09/29/25