What Happens When Federal Agents Kill a U.S. Citizen During Enforcement

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On January 7, 2026, federal immigration agents shot Renée Good while she sat in her Honda Pilot in Minneapolis. Seventeen days later, agents shot ICU nurse Alex Pretti while he was pinned to the ground. What happens when a federal agent kills a U.S. citizen turns out to be a question with no answer—only a confusing system of legal rules that contradict each other and leave gaps that make holding anyone responsible nearly impossible.

Two Deaths, Two Weeks, One City

Renée Good was sitting in her Honda Pilot on Portland Avenue on the morning of January 7, documenting ICE activity near a dual-language elementary school. Federal immigration agents had called for help after their vehicle got stuck in snow. Video analysis by ABC News shows what happened next, frame by frame: At 9:35:05 a.m., Good’s vehicle was stopped diagonally while other cars passed normally. At 9:36:58 a.m., she appeared to gesture for a Ford Explorer to pass in front of her. Agents arrived in an unmarked pickup with flashing lights. An ICE agent positioned himself at the front-left of her vehicle.

After Good was shot, bystanders pleaded with agents to let a physician check on her. They refused, saying they had their own medics. More than six minutes passed before firefighters arrived. Good was pronounced dead at Hennepin County Medical Center.

Seventeen days later, Alex Pretti—a 37-year-old ICU nurse at a VA hospital, union member, U.S. citizen with no criminal record—was shot by federal agents while pinned to the ground on a Minneapolis street. Video footage obtained by ABC News shows Pretti holding only a cellphone as agents tackled him. He had a valid permit to carry a concealed firearm, which was discovered during the scuffle. According to a DHS report, Pretti never attempted to reach for the weapon while on the ground.

Both cases were captured on video.

Why Victims Can’t Sue Federal Agents

Agents working for the federal government can’t be sued under the law that applies to state and local police. The Supreme Court has been steadily closing off the ability to sue federal officials for the past two decades.

The alternative—a federal law meant to handle claims against the government—has its own problems that make it nearly unworkable. The law doesn’t allow people who win their cases to recover attorney’s fees from the government. A victim with $30,000 in damages might face $50,000 in bills from their lawyer. Even with a contingency fee arrangement capped by law at 25 percent, the economics don’t work. As one University of San Diego law professor noted, “as a practical matter, no lawsuit alleging constitutional violation or tort by I.C.E. will be brought unless the monetary damages sustained by the citizen approach six figures.”

Federal courts interpret a provision shielding the government broadly. An agent’s decision to use force is treated as a policy choice, so the government can’t be sued. Case dismissed.

You don’t get a jury trial under this law. A judge decides—possibly a former government attorney with no obligation to follow jury instructions.

Civil rights lawyers call this a “legal black hole.” The individual agent is immune because of the Westfall Act, which makes the government the defendant instead of the individual agent. The government is immune because of the provision about judgment calls. The victim recovers nothing.

Qualified Immunity: The Catch-22

Even if a victim gets past those barriers, there’s another legal shield called qualified immunity. The protection shields government officials from civil liability unless the victim can point to an almost identical case where a judge already decided the conduct was illegal.

You can’t win unless there’s a prior case on point. But there will never be a prior case on point if every suit gets dismissed at the start.

The NAACP Legal Defense Fund has documented how this creates an impossible standard. An ICE agent in Minneapolis can point to the absence of a prior case in their federal appeals court, even if identical facts were litigated in other parts of the country. Each federal appeals court starts from scratch. The “clearly established law” required to overcome qualified immunity almost never exists.

For the Good and Pretti families, the calculus is grim. They have strong factual cases—video evidence of seemingly unreasonable force, no imminent threat, disproportionate response, fatal outcomes. But unless their damages exceed several hundred thousand dollars, no attorney willing to take the case on contingency would break even economically.

The law, as constructed, ensures federal agents can violate constitutional rights with near certainty they’ll face no personal civil consequences.

Why Criminal Prosecution Is Rare

States retain authority to prosecute federal agents for state crimes, but a constitutional rule called the Supremacy Clause prevents states from prosecuting federal agents for conduct within the scope of authorized federal duties. States can’t prosecute federal agents for conduct within their authorized duties, even if that conduct violates state criminal law.

The federal government rarely prosecutes its own agents. The Department of Justice’s civil rights division has authority to prosecute federal agents under a federal law that makes it a crime for federal agents to violate constitutional rights, but these prosecutions are extraordinarily rare. According to reporting, ICE’s litigation division was defending more than 350 tort claims nationwide, with plaintiffs collectively seeking over $55.5 billion in damages. The agency had paid out less than $1 million in settlements.

As of this writing, neither ICE agent Jonathan Ross, who killed Renée Good, nor the agents who killed Alex Pretti have been criminally charged. The FBI assumed control of investigating Pretti’s death, but federal investigations of federal agents rarely result in prosecution.

How Federal Shootings Are Investigated

There’s no law requiring a specific agency to investigate when a federal agent kills someone. No standards about how thorough the investigation has to be. No requirement to publicly release investigation results. No mechanism ensuring someone is held responsible if an investigation is inadequate.

For the Pretti case, DHS initially put Homeland Security Investigations in charge of the probe. Within days, that responsibility transferred to the FBI. The transfer came without clarity on why the original designation was inappropriate, whether HSI’s involvement had already compromised the investigation, or what powers the FBI had that HSI didn’t. The Department of Justice also started investigating whether civil rights were violated—meaning the same incident was potentially being investigated by two separate federal entities with no way for them to work together.

For the Good case, similar uncertainty surrounded the investigation. It remained unclear what standards would decide when the investigation was done, what would lead to charges being recommended, or what role state authorities would play.

Federal Judges Respond

Following the Good shooting and amid escalating ICE enforcement through Operation Metro Surge—which deployed roughly 3,000 federal agents to Minnesota, approximately 37 times the normal number—Minnesota Attorney General Keith Ellison and the cities of Minneapolis and Saint Paul filed a federal lawsuit claiming that the operation violated free speech rights, state sovereignty, and federal administrative law.

Federal judges across the country began criticizing widespread illegal and unconstitutional behavior by ICE. These weren’t controversial use-of-force cases. Federal agents were systematically violating the orders of federal courts themselves. This directly challenged the courts’ authority and the principle that everyone must follow the law.

Public Response and Congressional Action

Hundreds of businesses closed voluntarily in solidarity. Clergy marched and knelt in civil disobedience. Labor unions organized massive rallies. The strike, called “Day of Truth & Freedom” or “ICE Out of Minnesota,” was organized by community groups, labor unions, churches, and activists. The demands were explicit: ICE withdrawal from Minnesota, criminal charges for federal agents who killed Good and others, cuts to ICE funding, and prohibitions against federal agents wearing masks that hide their faces during enforcement operations.

After Pretti’s death, organizers announced plans for a nationwide strike for January 30, indicating the Minnesota uprising was expanding nationwide.

The strike immediately changed what Congress was willing to do. As Congress debated how much money to give DHS, Democrats said they would block funding unless ICE was reformed. Specific demands included all ICE and Border Patrol agents would have to wear body cameras, agents would need court-approved warrants before conducting raids, standards about when and how agents can use force, better training for agents, and prohibitions on tactics like wearing masks that obscured identification.

Body Cameras and the Warrant Problem

In late January 2026, DHS announced that all federal law enforcement agents in Minneapolis would be required to wear body cameras, with plans to expand the requirement nationwide as funding became available. President Trump stated that body cameras were generally good for law enforcement because “people can’t lie about what’s happening.”

The irony was sharp. In the Good case, video footage contradicted the official narrative. In the Pretti case, video showed conduct difficult to reconcile with official justifications. The body camera requirement was, in effect, a response to the fact that federal agents’ own conduct, when recorded, contradicted their own explanations of it.

As negotiations continued in Congress, lawmakers became aware of something more alarming: In May 2025, the acting ICE director issued a memo that appeared to authorize agents to enter private homes without court-approved warrants, relying instead on forms that immigration agents sign saying someone should be deported.

The Fourth Amendment protects people from police searching their homes without good reason. For nearly 250 years, American courts have required that searches and seizures in the home require a warrant issued by a neutral judge or magistrate. A warrant signed by an immigration agent isn’t neutral—the agent wants the deportation.

This memo contradicted what ICE had been teaching its agents for years. In a 2007 letter to Congress, the DHS Secretary had explicitly stated that “a deportation warrant is signed by an official, not a judge, and doesn’t give agents the same power to enter dwellings as a judicially approved search or arrest warrant.” ICE basic training as recently as 2021 had taught agents that “a deportation warrant alone doesn’t let agents search someone’s home.”

Yet the May 2025 memo appeared to let agents do exactly what the Constitution and ICE’s own standards said they couldn’t.

This memo led to real harm during Operation Metro Surge. Federal agents broke into the home of Scott Thao, a U.S. citizen, without a court-approved warrant, and refused to look at his ID even when he showed it, holding him at gunpoint in freezing temperatures while he wore only sandals and underwear. After realizing they’d entered the wrong home and that Thao was a citizen with no criminal record, agents returned him without apology. The man they sought was already in prison.

In another case, agents forcibly entered the home of Garrison Gibson, a Liberian man, without producing a court-approved warrant. A federal judge later said his arrest violated his constitutional right to be safe in his home and ordered his release.

On February 3, 2026, House Democrats sent a letter to DHS demanding the warrantless entry memo be rescinded immediately. “ICE doesn’t have the power to ignore any law, especially not the Constitution,” they wrote. “You must rescind this memo and adhere to the requirements of the Fourth Amendment by making sure your agents get a court-approved warrant before entering someone’s home without permission.”

Broader Pattern of Force

Agents fired at people at least 20 times since the Trump administration started aggressive enforcement in mid-2025, with at least five people killed and nine others injured. Federal agents fired rubber bullets and pepper balls at least 17 times, including incidents where pastors were shot with pepper balls while leading prayers at demonstrations.

Because there were no ways to hold federal agents accountable, they knew that even when their conduct appeared unjustified on video, the likelihood of personal civil liability or criminal prosecution was minimal.

Reform Proposals

In the weeks following the shootings in Minneapolis, Democratic lawmakers agreed that Congress should pass laws setting standards for how federal agents can use force instead of letting each agency decide for itself or having different courts interpret the Constitution differently.

The most detailed proposal would let people sue federal agents the same way they can sue state and local police—a change called the “Bivens Act” introduced to Congress in November 2025. The proposal would change the law to include federal agents, not state and local ones, so federal agents could be personally sued for violating constitutional rights.

Another proposal, the “Qualified Immunity Accountability Act,” would limit the legal shield that protects agents from being sued, to make it clear that federal agents can’t break the Constitution without facing consequences.

Other reforms included mandatory body cameras with activation policies, court-approved warrants required for enforcement operations in homes and sensitive locations, clear standards about when agents can use force based on what courts have already decided, and training to teach agents how to calm down tense situations.

What Comes Next

The deaths of Renée Good and Alex Pretti exposed what civil rights advocates, constitutional scholars, and federal judges have increasingly recognized: the laws that control how federal agents can use force don’t do enough to hold them accountable. Victims and families have no practical way to sue or get justice. Federal agencies know their agents will face almost no consequences for conduct that violates the Constitution.

Supreme Court decisions that make it hard to sue federal agents, a federal law that blocks most lawsuits against the government, the lack of federal laws setting standards for when agents can use deadly force, and the widespread use of qualified immunity have created a system where federal agents can’t be held responsible.

The crisis in Minneapolis forced people to question whether this system can continue. The demand for body cameras, warrant requirements, use-of-force standards, and ways for victims to sue represents a return to basic constitutional principles: that federal agents should operate under specific standards, that their conduct should be documented, that courts should be able to stop federal agents when they violate citizen rights, and that families should have meaningful avenues for seeking justice.

Congress will need to set specific standards for federal agencies instead of letting each agency make its own standards, and make it possible to sue federal officials instead of accepting protections that shield them from lawsuits that courts have created.

Until Congress passes new laws or courts change their decisions, federal agents will know they can break the law without facing consequences. The question is whether the crisis in Minneapolis will lead to the reforms needed to fix these problems, or whether it will be forgotten like other federal shootings that made people angry but didn’t lead to real change.

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