What Legal Protections Apply When Federal Agents Use Deadly Force?

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Immigration and Customs Enforcement agent Jonathan Ross fired three shots through the driver’s side window of a red Honda Pilot in south Minneapolis on January 7, 2026, at 9:30 in the morning. The driver, 37-year-old Renee Nicole Good—a U.S. citizen, a mother of three—died from a gunshot wound to the head. Federal authorities immediately characterized the shooting as justified self-defense, claiming Good had used her car as a weapon and attempted to run over officers. Minneapolis Mayor Jacob Frey, after reviewing video of the incident, called that characterization “bullshit.”

Federal agents operate under a fundamentally different accountability system than local police. Federal agents face fewer legal consequences. Federal agencies keep investigations secret. The legal rules that protect agents from being punished for excessive force are, in practical terms, nearly insurmountable.

Good’s death represents at least the fifth person killed by federal immigration officers in recent months during what the Trump administration describes as the “largest ever” operation. Federal agents have shot people in cars, federal agencies have claimed the shootings were necessary to protect officer safety, and video evidence has contradicted the official accounts.

What the Video Shows and What Federal Officials Said It Shows

Video footage that circulated within hours of the shooting shows Good’s Honda partially blocking East 34th Street and Portland Avenue. ICE agents approach from multiple angles. At least two agents try pulling open the driver’s door while a third positions himself in front of the car.

When Good attempts to drive away—moving forward—the agent in front draws his weapon and fires three shots through the driver’s side window. He appears to step backward and to the side as he fires. Whether the car made contact with him before the shooting began remains unclear from available footage.

After the shots, Good’s car accelerates and crashes into two parked cars before stopping. She was transported to Hennepin County Medical Center and pronounced dead.

The Department of Homeland Security‘s version: Good used her car as a weapon, “attempting to run over law enforcement officers in an attempt to kill them.” DHS Secretary Kristi Noem called it “an act of domestic terrorism” and said the officer “followed his training, did exactly what he’s been taught to do in that situation.”

One eyewitness described something different: “The car parked in the road and then a bunch of ICE agents walking up, screaming at her to move, and then when she backed up and then started to turn away to move and to get out of their way, then one of [the agents] jumped in front of the car.”

What the Constitution Says About When Officers Can Shoot

The legal foundation comes from a 1985 Supreme Court case involving a Memphis police officer who shot an unarmed teenager fleeing from a burglary. The Court established that officers can use deadly force when they have good reason to believe a person poses an immediate, urgent danger of death or serious injury. That standard applies to every law enforcement officer in America, whether they work for a city police department or a federal agency.

But federal agencies have imposed stricter rules on themselves. The Department of Justice’s policy states that “firearms should not be used simply to disable a moving vehicle” and limits deadly force to narrow circumstances. An officer can use deadly force only when there’s a reasonable belief that someone poses an immediate, urgent danger of death or serious injury.

Federal policy states that shooting at a moving car is authorized only when “no other objectively reasonable defensive option exists”—and the policy identifies “moving out of the path of the vehicle” as such a reasonable alternative.

The Department of Homeland Security’s 2023 guidelines mirror this approach. Officers “may use deadly force only when necessary” based on reasonable belief of an immediate, urgent danger. DHS rules make clear: if you can step out of the way, you’re supposed to step out of the way instead of shooting.

When New York City banned firing at or from moving cars in 1972—after a shooting killed a 10-year-old passenger in a stolen car—research showed the policy worked. Fewer bystanders were struck by police gunfire. Fewer people died in police shootings overall.

Organizations like the Police Executive Research Forum and the International Association of Chiefs of Police have recommended similar limits, warning that shooting at cars creates serious risks from stray gunfire or from crashes if the driver is hit.

The tactical doctrine is straightforward: don’t position yourself in front of a car as a tactic to control a suspect. If you do, you’ve created what law enforcement training calls putting yourself in danger unnecessarily—a situation that potentially weakens any legal justification for using lethal force later.

As one former senior Homeland Security Investigations agent with 25 years of experience put it: “I’ve been conducting stops and approaches for 25 years … I never ever wanted to be intentionally in front of the vehicle.”

The Immunity Shield: Why Federal Agents Are Nearly Impossible to Prosecute

Federal agents benefit from legal protections that make accountability extraordinarily difficult. These protections operate at multiple levels, each one creating a separate barrier to prosecution or civil liability.

First: A constitutional rule that federal law overrides state law means states generally cannot use criminal prosecution to interfere with federal officers performing their duties. Minnesota prosecutors have jurisdiction to charge Jonathan Ross with state crimes like manslaughter or murder. But Ross could move the case to federal court and argue immunity, placing on the state the burden of proving his actions were outside the scope of his official duties or were objectively unreasonable or clearly unlawful.

In late 2025, Deputy Attorney General Todd Blanche stated that arrests of federal officers performing their duties would be “illegal and futile.” State prosecutors face significant structural barriers even attempting to charge federal agents.

Second: A judge-made rule that protects government officials from civil damages unless someone can prove that the official violated a constitutional right and that the violation was obviously illegal based on existing court decisions. This requires that existing case law must have placed the violation “beyond debate” as unlawful. In cases involving shootings at cars, courts frequently find this immunity applies because fact patterns vary enough from published precedent.

Third: Federal agencies have immunity from lawsuits unless Congress allows them. Congress created one exception: the law that allows people to sue the federal government for wrongful death. But these suits face their own limitations: lawyers can only take 20-25% of any settlement, which discourages lawsuits. There’s no extra punishment money to discourage future misconduct. The government can claim immunity by saying it was making policy decisions.

A 2022 Supreme Court decision made it much harder to sue federal officers directly, particularly in immigration contexts. Before that decision, people could sometimes sue federal officers directly for violating constitutional rights. The Supreme Court has now made such claims increasingly difficult to pursue.

The most realistic path for civil liability is a wrongful death suit against the United States itself. But such suits are tried before a judge, not a jury. Federal courts have developed doctrine limiting circumstances under which these claims can proceed in deadly-force cases where there’s disagreement about what happened. Even successful claims face the fee caps and damage limitations that reduce their impact.

For criminal prosecution at the federal level, federal prosecutors would need to prove not merely that Ross violated constitutional standards, but that he specifically and intentionally knew his conduct was unlawful or deliberately ignored constitutional rights or didn’t care if they were violated. That’s the federal law that makes it a crime for government officials to violate people’s rights.

Historically, federal prosecutors rarely charge federal law enforcement officers with crimes for use-of-deadly-force incidents.

The Investigation Problem: Who Controls the Evidence?

On January 7, shortly after Good was shot, an initial agreement was reached: the FBI, the U.S. Attorney’s Office, and Minnesota’s Bureau of Criminal Apprehension would conduct a joint investigation. Later that same day, the FBI took over the investigation and excluded state investigators. The BCA would no longer have access to case materials, scene evidence, or investigative interviews.

BCA Superintendent Drew Evans stated that without access to evidence and witness information, the BCA couldn’t do its job.

Minnesota prosecutors retained legal authority to investigate and prosecute Ross for state crimes. But performing such an investigation without access to scene evidence, witness statements, and forensic findings collected by the FBI would be substantially more difficult. Federal investigators control both the evidence and the narrative in a case where the federal government has an institutional interest in the outcome.

Since George Floyd’s murder, state and local police departments face intensive scrutiny following officer-involved shootings. New rules require independent investigations and body cameras. Federal law enforcement agencies operate with broader immunity protections and less public oversight.

When CBS News asked whether any CBP or ICE agents had been disciplined as a result of recent immigration raids, the response was that none had been. ICE’s head of training stated he had not seen any uptick in discipline or investigations despite the pattern of shootings.

The Pattern: At Least Five Deaths in Five Months

Federal officers have fatally shot at least four other people in the last five months during the Trump administration’s escalated campaign.

In September 2025, Silverio Villegas González was killed while reportedly trying to flee from ICE officers in a Chicago suburb. Federal authorities claimed he had attempted to drive toward officers. Body camera video later suggested the officer’s injuries were minor.

In December 2025, a Border Patrol agent killed a 31-year-old Mexican citizen while attempting to detain him in Rio Grande City, Texas.

On New Year’s Eve 2026, an off-duty ICE agent used his service weapon to shoot a man in Los Angeles, with authorities claiming the man had raised a rifle at the officer.

In October 2025, a Border Patrol agent shot Marimar Martinez five times during an operation similar to the one in Minneapolis. Federal authorities claimed Martinez had “ambushed” and “rammed” agents with her car, characterizing her as a “domestic terrorist.”

Security camera video and body camera footage later revealed that the Border Patrol agent had steered his own car into Martinez’s truck. The government’s account was contradicted entirely by the video evidence. Charges against Martinez for assaulting a federal officer were dropped. A federal judge ordered the video withheld from public release.

According to The New York Times, in the last four months federal officers have fired on at least nine people while they were in their cars.

Beyond shootings, there are documented instances of federal agents pointing weapons at activists, elected officials, and community members. Illinois State Representative Hoan Huynh reported that agents blocked his car and pointed a gun at him while he was attempting to alert community members about ICE presence. A pregnant Illinois woman reported that a federal agent pointed a gun through her car window after she honked her horn to alert people that ICE was nearby. In Chicago, a combat veteran alleged in a court filing that a federal officer said “bang, bang” and “you’re dead, liberal” while pointing a handgun at him.

Homeland Security has routinely defended shootings as necessary to protect officer safety. Video and witness evidence have disputed their accounts in multiple cases. After federal agents fatally shot González in Chicago, DHS claimed an officer was seriously injured, yet body camera video captured the officer saying his injuries were “nothing major.”

The Context: 2,000 Federal Agents in One Metropolitan Area

The Trump administration deployed approximately 2,000 federal agents to Minneapolis-St. Paul, marking one of the largest federal law enforcement mobilizations in recent years. According to DHS, the operation was aimed at both immigration work and investigation of a massive fraud scandal involving welfare programs in Minnesota.

The effect has been to flood a major urban center with federal agents whose primary training and experience may be in border work rather than community policing or urban tactical operations. Police affairs consultant Bill Kushner noted that ICE agents’ “role was never designed to deal with crowds of people.”

A lawyer for Marimar Martinez suggested the problem: “You’re taking these agents from outside areas, away from the border, and placing them into cities they’re not from into situations that are not controlled, and they are not they’re not prepared for this, and they’re not prepared for the general public not being fans of them.”

Federal agents deployed to urban centers may lack adequate training in calming down tense situations without using force, community interaction, and urban tactical awareness—yet they operate under federal immunity protections that may exceed those of local officers.

Minneapolis Mayor Jacob Frey characterized the federal presence as “recklessly using power” and stated: “ICE — Get the fuck out of Minneapolis. We do not want you here. Your stated purpose for being in this City is to create some kind of safety, but you are doing exactly the opposite. Federal agents are causing chaos in our city and making our community less safe.”

Governor Tim Walz issued a “warning order” to prepare the Minnesota National Guard for possible deployment, suggesting state leaders anticipated potential civil unrest following the shooting.

The Specific Details That Complicate the Government’s Narrative

Jonathan Ross, the agent who shot Good, is described as an experienced officer with over ten years of service, assigned to an ICE Special Response Team. Ross was the same officer who had been dragged approximately 100 yards by a car in Bloomington, Minnesota, the previous June when he attempted to conduct a traffic stop—an incident that left him with significant lacerations requiring 33 stitches to his arm and hand.

Vice President J.D. Vance publicly defended Ross shortly after the shooting, stating that “it’s not surprising he feared for his life” given the prior incident. Should an officer with documented trauma from being dragged by a car be deployed to situations involving civilians in cars without enhanced training and supervision addressing how traumatic prior incidents affect subsequent threat assessment?

Legal experts and former federal officials noted that video evidence appears to show Ross holding or photographing the driver with a cell phone in his left hand while drawing his weapon with his right hand, raising questions about his positioning and focus at the moment the shooting began.

Former ICE officials told CBS News: “At a certain point, you need to understand not to put yourself in these positions. Why did you put yourself in front of the car? You’re staging the scene. Tactically, why would you put yourself in that position? That’s why training is so important. That’s why positioning is so important.”

According to use-of-force experts, courts can analyze individual shots separately. A first shot while the officer was positioned in the car’s path might be legally justified under different circumstances than a second or third shot fired after the car had passed the officer. This distinction between shots fired while “in-path” versus shots fired after the car has “passed” is legally decisive, because the constitutional analysis of whether force was what a reasonable person would think was necessary can change as circumstances change from moment to moment.

When video shows an officer stepping back and to the side while firing—rather than being directly in the car’s path—courts may view this as evidence that the officer perceived diminishing rather than immediate, urgent danger. An officer who positioned himself in front of a car and then stepped aside while firing could be viewed as having successfully avoided the threat through tactical positioning, thereby undermining the claim that deadly force was necessary.

What Good Had a Right to Do

Good had every legal right to drive away from individuals who had not informed her she was under arrest, had not placed her under arrest, and had not detained her for any lawful purpose.

Good was not a suspect in a violent crime. She was a U.S. citizen whose car happened to be parked in the roadway during an ICE operation related to alleged fraud. Under constitutional rights against unreasonable searches and seizures, Good had a legal right to drive away from individuals approaching her car without lawful authority to stop her.

John P. Gross, a professor at the University of Wisconsin School of Law who has written extensively about officers shooting at moving cars, stated: “If this woman was blocking the street and a law enforcement operation, they are entitled to arrest her. What they are not entitled to do is to use deadly force to arrest her. From watching the video, this seems like an egregious example.”

The critical legal question becomes whether, in the seconds between when agents approached Good’s car and when Ross fired three shots, the agents had the legal right to stop Good and whether driving away posed an immediate, urgent danger of death or serious injury.

What Happens Next

The FBI is conducting the investigation. Whether federal prosecutors will charge Ross remains to be seen, but history suggests they probably won’t. Prosecutors must prove the officer intentionally violated the law.

Minnesota prosecutors could theoretically pursue state charges. The Hennepin County Attorney’s Office stated “the bottom line is yes, we have jurisdiction,” but also noted that prosecutors were “still gathering facts” and that “charging decisions would come later, if at all.” Without access to FBI investigative materials, pursuing state charges would be substantially more difficult.

Good’s family can pursue a wrongful death claim against the United States government. This is probably the most realistic path for any form of accountability. But these suits face the limitations described earlier: capped attorney fees, no punitive damages, trials before judges rather than juries, and federal courts’ skepticism of such claims in cases where there’s disagreement about what happened.

Direct civil suits against Ross personally are largely foreclosed by the legal rule that protects government officials from being sued and the Supreme Court’s restrictions on lawsuits against federal officers personally for violating constitutional rights.

Internal investigations by DHS or the Justice Department could result in anything from a warning to being fired. But these investigations happen in secret and results aren’t made public.

Based on historical patterns: no criminal charges, a potential settlement paid by taxpayers rather than the officer or agency, and no meaningful change to federal use-of-force policies or training.

The Accountability Gap

Since George Floyd’s murder, state and local police departments have implemented enhanced accountability mechanisms. Independent investigation units. Body camera requirements. Increased prosecutorial willingness to charge officers with crimes. Committees that review when officers use force, and community input.

Federal law enforcement agencies operate with substantially broader immunity protections and less public oversight. When asked whether any agents had been disciplined for aggressive tactics, federal officials said none had been. This suggests either that no policy violations occurred—despite video evidence contradicting official accounts in multiple cases—or that accountability mechanisms aren’t being used.

The legal rules create a situation where federal agents have more protection than local officers while potentially having less training for the urban contexts in which they’re now operating.

The Justice Department has remained largely silent on the pattern of federal agent violence, despite its own policies establishing stricter standards than constitutional minimums require. These policies exist because research shows they work: fewer people die and officers stay safe. But policies only matter if they’re enforced.

The Minneapolis shooting occurred in a city still processing the trauma of George Floyd’s murder—a case that sparked a national reckoning about police accountability and use of force. Local police in Minneapolis now operate under enhanced scrutiny and accountability mechanisms, while federal agents deployed to the same city operate with near-total immunity from the consequences that would face local officers in comparable circumstances.

Whether this case catalyzes any change to federal use-of-force policies, training, or accountability mechanisms remains to be seen. The video evidence, the pattern of shootings, and the gap between federal policy and federal practice have created a moment where the question of what legal protections apply when federal agents use deadly force has become impossible to ignore.

Federal agents have more protections than most people realize. More than local officers receive. Substantially more than the families of those killed by federal agents will ever be able to overcome.

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