On February 19, 2026, a federal judge in West Virginia released a 21-year-old Salvadoran man from immigration detention and, in doing so, produced one of the most searingly direct opinions in recent American legal history.

Anderson Jesus Urquilla-Ramos had come to the United States fleeing violence in El Salvador. He had a pending asylum case. He had valid work authorization. He had a valid driver’s license. On a West Virginia highway, a traffic stop — pretextual, for a license plate cover — became the occasion for his arrest by federal agents who wore masks, carried military-style weapons, drove unmarked vehicles, and presented no warrant of any kind.

Judge Joseph R. Goodwin of the Southern District of West Virginia was not willing to dress that up in careful legal language. His opinion in Urquilla-Ramos v. Trump opens with a passage that is worth quoting in full:

“Antiseptic judicial rhetoric cannot do justice to what is happening. Across the interior of the United States, agents of the federal government — masked, anonymous, armed with military weapons, operating from unmarked vehicles, acting without warrants of any kind — are seizing persons for civil immigration violations and imprisoning them without any semblance of due process. The systematic character of this practice and its deliberate elimination of every structural feature that distinguishes constitutional authority from raw force place it beyond the reach of ordinary legal description. It is an assault on the constitutional order. It is what the Fourth Amendment was written to prevent. It is what the Due Process Clause of the Fifth Amendment forbids.”

He granted the writ of habeas corpus. He ordered Urquilla-Ramos returned to West Virginia after the government attempted to moot the case by shuttling him from West Virginia to Texas, then to Washington State, after the court had issued a stay. The government had also conceded the factual allegations at the show cause hearing.

It was a remarkable ruling. It was also, by the court’s own count, the fifth such ruling in the Southern District of West Virginia alone in 2026.

The Pattern

Judge Goodwin cited four prior cases from his own district — Aroca, Solano, Gonzalez, and Umarov — each raising substantially identical constitutional claims against substantially identical tactics. Those cases are not outliers. Federal courts across the country have been issuing injunctions, temporary restraining orders, and habeas grants against the administration’s interior immigration enforcement campaign at a pace that has no recent precedent.

In the District of Minnesota, a court noted that ICE had violated court orders in 74 separate cases — 96 violations in total — at the time of its ruling in Juan T.R. v. Noem. In the District of Massachusetts, Judge William Young called the practice of masking ICE agents “squalid and dishonorable,” comparing the visual of armed, masked federal agents operating without identification to the imagery of the Ku Klux Klan — a comparison Judge Goodwin cited approvingly. In the District of D.C., Escobar Molina v. DHS rejected the administration’s justifications for warrantless civil arrests on overlapping grounds.

These are not ideologically uniform courts or judges. They are applying the same constitutional text to the same factual pattern and reaching the same conclusions. That convergence is significant.

The Judges

Judge Joseph R. Goodwin was appointed to the federal bench by President Bill Clinton in 1995. He has served the Southern District of West Virginia for three decades. He is not a firebrand; his record is that of a careful, experienced district judge who has handled everything from coal company litigation to complex criminal cases. His language in Urquilla-Ramos is not the language of an ideologue. It is the language of a judge who has looked at the same fact pattern five times and is no longer willing to pretend that the rules permit what he is seeing.

Judge William Young, who issued the Massachusetts ruling, was appointed by President Ronald Reagan in 1985. His characterization of masked federal agents as “squalid and dishonorable” carries particular weight precisely because it comes from a Reagan appointee.

The breadth of the judicial coalition here — Clinton appointees, Reagan appointees, judges from West Virginia, Massachusetts, Minnesota, the District of Columbia — reflects something important: the constitutional objections to this enforcement campaign are not the province of any one ideological corner of the federal judiciary.

The Constitutional Stakes

The Fourth Amendment analysis in Urquilla-Ramos centers on a question that sounds simple but has profound implications: can a government agent exercise state power over a person without identifying himself as a government agent?

Judge Goodwin’s answer is no, and his reasoning is worth following. A warrantless arrest, even when it falls within an exception to the warrant requirement, still must be reasonable. Reasonableness, as the Supreme Court has long held, is not purely an after-the-fact inquiry — it depends in part on the context in which force is applied and whether the person being seized has any basis to understand the nature and authority of the seizure. An anonymous figure in a mask, driving an unmarked vehicle, pointing a weapon, gives the person being seized — and any witness to the scene — no information by which constitutional authority can be distinguished from kidnapping.

Judge Goodwin put it directly: “Force without a face, which is another name for the thing the Fourth Amendment was written to prevent.” And: “An anonymous government is no government at all.”

The Fifth Amendment analysis is, if anything, cleaner. The procedural due process requirements for civil immigration detention — notice, a hearing, a neutral decisionmaker — were not met. The government moved Urquilla-Ramos across jurisdictions after a court issued a stay, behavior the opinion treats not as an administrative misstep but as a deliberate effort to deprive the court of jurisdiction over a case it had already taken.

Judge Goodwin’s sharpest line on this conduct comes from his earlier Aroca opinion, which he quoted here: “A statutory violation is a failure to follow the law. A knowing constitutional violation is a refusal to be bound by it.”

The Administration’s Response

The administration’s conduct in Urquilla-Ramos — moving the petitioner to Texas, then Washington State, after the court issued a stay — fits a documented pattern. The District of Minnesota’s observation that ICE had violated court orders in 74 cases (96 violations total) is not an anomaly. Federal courts have repeatedly found that the administration has transferred detainees to avoid jurisdiction, refused to comply with return orders, and in some instances claimed that compliance was impossible after the fact.

Administration officials and allied lawmakers have responded not by defending their conduct in court, but by attacking the courts. President Trump has called for the impeachment of federal judges who ruled against his deportation orders, a move Chief Justice Roberts publicly rebuked, stating that “impeachment is not an appropriate response to disagreement concerning a judicial decision.” Senate Republicans have joined the calls, and House members have filed formal articles of impeachment against multiple judges. This pressure campaign has not, so far, produced the results its architects presumably intend: judges are continuing to issue rulings.

What the Supreme Court Has Not Done

As of this writing, the Supreme Court has not intervened to address the pattern of constitutional violations described in these rulings. The Court has taken up discrete procedural questions in immigration cases — venue, the proper form of relief, the scope of class actions — but it has not issued any ruling that resolves the underlying Fourth and Fifth Amendment questions that courts from West Virginia to Minnesota have been answering the same way.

That silence is, in some respects, a choice. The administration has had ample opportunity to seek emergency stays of district court rulings. The Supreme Court’s willingness — or unwillingness — to use its emergency docket to shield the administration from compliance with lower court orders will be among the most consequential signals the Court sends this term.

The current Court’s record on immigration enforcement suggests that at least some justices are sympathetic to broad executive authority in this space. But the specific questions now arriving from district courts — can the government arrest people without warrants using anonymous, masked agents? can it move detainees to defeat habeas jurisdiction? — are not questions with obvious answers in the administration’s favor, even under the Court’s most deferential immigration precedents.

The constitutional minimum, as Judge Goodwin put it, is that the government must have a face. Whether the Supreme Court agrees will define the limits of what the executive branch can do to people on American soil.

Sources