ICE, like any other law enforcement agency, must have a judicial warrant in order to enter a home without consent. But they rarely do. In the absence of a judicial warrant authorizing entry, ICE agents have taken to gaining access to residences through deception, or a "ruse," a tactic that many courts have found to violate the Fourth Amendment.  Yet ICE’s memoranda instructing agents about the use of ruses, issued in 2005 and 2006,  do not acknowledge any constitutional limitations on the use of ruses, by implication permitting and encouraging agents to misrepresent themselves and their purpose.