A U.S. District Court recently denied a government application for an administrative inspection warrant to enter a private business for the purpose of searching for and seizing undocumented immigrants and investigating a pattern or practice of employing unauthorized aliens (sometimes referred to as a “Blackie’s” warrant after a seminal case, discussed below). Unlike a criminal search warrant, administrative inspection warrants may allow a government agency to search a premises for a civil administrative purpose (as opposed to a criminal investigation) and may generally be issued pursuant to a less rigorous standard as compared to criminal search warrants. In In re Sealed Search Warrant Application, the court rejected the government’s efforts to obtain an administrative inspection warrant rather than a criminal search warrant, reasoning that it could not issue an administrative inspection warrant in the context of a workplace immigration raid based on a lesser showing than that required for criminal search warrants under the Fourth Amendment. No. CV 3:25-MC-05067, 2025 WL 1499054 (S.D. Tex. May 27, 2025).
