DENVER — ACLU of Colorado, the Meyer Law Office, and Olson Grimsley Kawanabe Hinchcliff & Murray, LLC filed a lawsuit against the Trump administration today to enjoin Immigration and Customs Enforcement (ICE) from conducting warrantless arrests in Colorado without probable cause that a person is a flight risk and in the country without proper legal documentation. The lawsuit also seeks class certification for people who have been or will be subject to ICE’s warrantless arrests.

The lawsuit is brought on behalf of Refugio Ramirez Ovando, a 43-year-old father and Lawful Permanent Resident who has lived in Colorado for 20 years, Caroline Dias Goncalves, a 19-year-old University of Utah student and Dreamer who was brought to the country as a child and has lived in the U.S. for more than 12 years, J.S.T., a 36-year-old asylum seeker who has lived in Colorado for 15 years, and G.R.R., a 32-year-old father and business-owner who has lived in the U.S. for 11 years.

The lawsuit alleges that ICE is conducting indiscriminate stops and arrests in violation of the law without making the required determinations about people’s immigration status or flight risk; ICE agents instead arrest and detain people because of their skin color, accent, or perceived nationality, all to fulfill arbitrary arrest quotas set by Trump administration officials.

Federal law requires that ICE agents must have probable cause to believe that an individual is both “in the United States in violation of any [immigration] law,” and the individual “is likely to escape before a warrant can be obtained for his arrest.” Agents must make individualized determinations for each person before conducting a warrantless arrest. This has been the law for decades: ICE officers simply cannot indiscriminately conduct warrantless arrests.

“People are terrified that masked agents will snatch their loved ones or neighbors from the street because an ICE agent believes they look different or speak with an accent. This is unacceptable,” said Tim Macdonald, ACLU of Colorado legal director. “The courts must see ICE’s actions for what they are: an unlawful abuse of power that must be stopped.”

“The true illegality here is ICE’s flagrant disregard of federal law,” said Hans Meyer, owner of the Meyer Law Office, and immigration attorney for the plaintiffs. “The courts must act to halt this widespread and egregious ICE practice of arresting people without warrants based on how they look, how they speak, or simply because of who they are with. This practice is a frontal assault on our communities to advance Trumps’s mass deportation agenda.”

Since President Trump’s inauguration in January 2025, ICE has dramatically increased the number of immigration arrests. ICE has raided apartment complexes, homes, businesses, and parking lots, where federal agents have used military-style tactical gear to intimidate and apprehend people. Federal agents have now escalated to making ‘collateral arrests’ of bystanders who happen to be in proximity to someone who ICE deems a person of interest.

Ramirez has lived in Colorado for the past 20 years. He has four U.S. citizen children and is now a Lawful Permanent Resident in the U.S. One morning in May, as he left his home for work, he was followed by unmarked vehicles. ICE officers pulled him over, and even though they asked no questions about his ties to the community, they arrested him and took him to the detention center in Aurora. He was held for more than 90 days. Officers later admitted that he was not the person that they had been looking for but arrested him anyway.

In Goncalves’ case, she was stopped by Mesa County Sherriff’s Office Investigator Alexander Zwinck for allegedly following a truck too closely. Zwinck asked where she was from, commenting that Goncalves had “a bit of an accent.” After pressing her for more information, Goncalves revealed that she was born in Brazil and moved to Utah with her parents as a child. Zwinck then alerted ICE about Goncalves’ whereabouts; she was stopped by ICE a few miles away, arrested, and detained for 15 days. ICE agents made no effort to evaluate whether Goncalves was a flight risk, and if they had, they would have learned that she was a scholarship student in college with a stable home and family life. Colorado Attorney General Phil Weiser filed a civil complaint against Zwinck in July 2025 for violating state laws that limit collaboration between local law enforcement and federal immigration officers. Zwinck has since resigned from the Mesa County Sheriff’s Office.

G.R.R. was waiting to pick up a friend from a Colorado Springs nightclub. His friend was not answering his phone, so G.R.R. entered the club to look for him. As G.R.R. was exiting, hundreds of federal agents (including ICE), donning tactical gear and assault weapons, raided the establishment. They flooded the nightclub with tear gas and flash bangs. Terrified, G.R.R. hid under a car, where an officer then ordered him to get out at gunpoint. Despite G.R.R.’s compliance, the officer shoved him to the ground, and G.R.R.’s hand was sliced open. The officer searched G.R.R’s wallet, found a Mexican consular card, and then confiscated both his phone and wallet, before taking G.R.R. to an onsite EMT who recommended he get stitches. The officer ignored this recommendation, told the EMT to put a band-aid on G.R.R.’s wound, and placed him in handcuffs. ICE officers did not ask anything about G.R.R.’s ties to the community and his long-term presence in Colorado. G.R.R was then held at the detention facility in Aurora for 50 harrowing days.

J.S.T. was driving to work when federal agents swarmed the parking lot of his apartment complex. Federal agents blocked the exits, stopped J.S.T., and questioned him. Agents had no warrant for his arrest and made no effort to determine his ties to the community, including his long-term employment. The agent took J.S.T.’s driver’s license, ordered him to exit the vehicle, zip tied his hands, and took him into custody. J.S.T. was held at the Aurora facility for over a month, despite agents never having obtained a warrant for J.S.T’s arrest.

“Regardless of the color of our skin, the language we speak, or the neighborhoods we live and work in, the law protects us from these types of warrantless arrests,” said Kenzo Kawanabe, partner at Olson Grimsley. “Each of us is protected from being rounded up and arrested in mass raids meant to meet arbitrary government quotas.”

In addition to Meyer, Kawanabe, and Macdonald, the legal team includes ACLU of Colorado Senior Staff Attorneys Sara Neel, Emma Mclean-Riggs, Annie Kurtz, Scott Medlock, and Olson Grimsley Kawanabe Hinchcliff & Murray, LLC’s Bianca Miyata, Katie Wright, Nicole Hollingsworth, and Sean Grimsley.

View the complaint below.

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