When immigration agents have shot at least 40 people and killed 11 since January 2025 — including a man authorized to work in the United States and a construction worker with a pending permit application — what do religious traditions and the Constitution say about lethal force in civil immigration enforcement?
Being in the country without authorization is a civil violation. Fleeing a traffic stop is not a capital offense. <em>Tennessee v. Garner</em> settled forty years ago that an officer may not shoot a fleeing suspect who poses no serious threat, and the Fifth Amendment's protection of "any person" does not have a citizenship exception. Religious traditions set the same floor from the other direction: force must be proportional to the danger, the taking of a life carries the weight of a world, and the sojourner — the person whose status makes them least able to call for help — is the one the commands single out for protection. Officers face real risks and some of these shootings may prove justified. What the record shows is 40 shootings and 11 deaths in eighteen months, a man with lawful work authorization among the dead, and an accountability structure in which the federal agent who fires is reviewed by his own agency and is largely beyond the reach of remedies that would apply to a city police officer doing exactly the same thing. That gap is the thing to fix regardless of what one believes about immigration.
Religious perspectives
Religious traditions do not deny that officers may sometimes need to use force. What they insist on is proportionality — that the force used bear some relationship to the harm being prevented — and they are especially severe about force used against those who pose no threat.
Judaism: The Torah's framework for justified force turns on immediacy of danger: the principle of rodef (the pursuer) permits lethal force only to stop someone actively threatening a life. Absent that, the taking of a life is shefichut damim — bloodshed. The Talmud's principle that "whoever destroys a single soul, Scripture accounts it as if he had destroyed an entire world" (Sanhedrin 4:5) sets the weight the tradition assigns each death. A civil violation — being present without authorization, or fleeing a stop — is not the kind of danger the tradition recognizes as justifying lethal force.
Christianity: The Christian tradition's treatment of legitimate authority (Romans 13) has always been paired with the requirement that authority act justly. Augustine's and Aquinas's development of proportionality applies to policing as well as war: force must be the minimum necessary to the legitimate end. Jesus' words to Peter — "put your sword back in its place, for all who draw the sword will die by the sword" (Matthew 26:52) — came in a moment when Peter believed force was justified to prevent an unjust arrest, and Jesus refused it.
Islam: "Whoever kills a soul unless for a soul or for corruption done in the land — it is as if he had slain mankind entirely" (Quran 5:32). The verse establishes both the gravity of taking a life and the narrowness of the exceptions. Islamic jurisprudence on the use of force by authorities requires proportionality and treats the killing of someone who poses no threat as unjustified regardless of their legal status.
The stranger, again: The Torah's thirty-plus commands regarding the ger — the sojourner living among you — are not conditional on documentation. "You shall not oppress a stranger, since you yourselves know the feelings of a stranger, for you also were strangers in the land of Egypt" (Exodus 23:9). The command names precisely the vulnerability at issue: the person whose status makes them least able to call for protection.
The honest counterweight: Immigration officers face real dangers, including vehicles used as weapons, and no tradition asks an officer to accept death rather than defend himself. Some of the 40 shootings may well have involved genuine threats. The traditions' concern is with the pattern and with the accountability structures — whether each use of lethal force is examined by someone independent, and whether the answer changes depending on who was killed.
Constitutional & legal framework
Immigration enforcement is a civil function, not a criminal one — and that distinction shapes what the Constitution permits when agents use deadly force.
The record: According to compiled tracking, immigration agents have been involved in at least 40 shootings since January 20, 2025, resulting in 11 deaths. Two occurred in a single week in July 2026. On July 7, ICE agents shot and killed Lorenzo Salgado Araujo, 52, during an attempted traffic stop in Houston's East End; he was a Mexican national living in the U.S. without authorization but with a pending work-permit application, and was reportedly on his way to a construction job. On July 13, ICE officers shot and killed Joan Sebastian Guerrero, 26, in Biddeford, Maine; Guerrero was a Colombian national who was authorized to work in the United States. In both cases DHS stated that the driver attempted to flee and that officers fired out of concern for public safety.
The Fourth Amendment standard: Deadly force by a government officer is a "seizure" governed by the Fourth Amendment. Tennessee v. Garner (1985) held that an officer may not use deadly force to prevent the escape of a fleeing suspect unless the officer has probable cause to believe the suspect poses a significant threat of death or serious physical injury. Graham v. Connor (1989) established that the reasonableness of force is judged from the perspective of a reasonable officer on the scene. Together they establish that flight alone does not justify shooting — a principle that applies with particular force when the underlying matter is a civil immigration violation rather than a violent felony.
The vehicle question: Courts have repeatedly addressed shootings at moving vehicles. Many police departments prohibit firing at a vehicle solely because it is moving toward or away from an officer, on the reasoning that shooting the driver of a moving car creates rather than reduces danger to the public. Whether ICE follows comparable restrictions, and what its use-of-force policy actually requires, has been the subject of congressional inquiry.
The accountability gap: Local police shootings are typically investigated by an outside agency, reviewed by a district attorney, and subject to civilian oversight boards, state decertification processes, and municipal liability. Federal immigration agents sit outside most of that architecture. DHS investigates its own; there is no equivalent to a state decertification body; and Bivens actions (the vehicle for constitutional damages claims against federal officers) have been substantially narrowed by the Supreme Court, most recently in Egbert v. Boule (2022), which declined to extend Bivens to a Border Patrol agent. The practical result is that the remedies available against a city police officer often are not available against a federal agent who does the same thing.
The due process floor: The Fifth Amendment's Due Process Clause protects "any person," and the Supreme Court has long held that noncitizens within the United States are covered. A person's immigration status does not change the constitutional standard governing when an officer may shoot them.
The honest other side: Immigration officers do face genuine risk, traffic stops are among the most dangerous encounters in law enforcement, and an officer who reasonably fears for his life may lawfully use deadly force. Each incident turns on facts that early reporting frequently gets wrong. The constitutional concern is not that any particular shooting was necessarily unlawful; it is that the volume has risen sharply, that the accountability mechanisms that apply to other officers largely do not apply here, and that the people being shot include some with lawful work authorization.
See: Fourth Amendment → | Tennessee v. Garner (1985) → | Graham v. Connor (1989) →
Sources cited:BibleTorahQuranConstitutionSupreme Court