The Deaths We Didn't Count

Earlier this year, in partnership with lawyer and journalist Andrew Free, the UCLA Law Behind Bars Data Project (BBDP) published the first comprehensive database of the more than 280 deaths that have occurred in Immigration and Customs Enforcement (ICE) detention since the agency was first created in 2003.

Nonetheless, many people who died during immigration enforcement are missing from our data. In this post, we explain the scope of the dataset, what it includes and excludes, and why it takes this shape.

Our database of deaths in ICE detention excludes some of the most well-known and high-profile killings by immigration enforcement agents, among them, Renée Good, Keith Porter Jr. Alex Pretti, and Ruben Ray Martinez. These gaps exist because, in keeping with the BBDP mission to track deaths in carceral facilities, we chose to include only deaths that occurred between the time ICE booked someone into custody and their release from custody. We also did not count deaths that occurred in other parts of the immigration detention system, such as Customs and Border Protection (CBP) facilities or Office of Refugee Resettlement shelters for unaccompanied children.

There is also a logistical reason for excluding these deaths: the federal government continues to make it hard to obtain data concerning the conduct of ICE agents, and the immigration enforcement system spans a patchwork of federal, state, and local agencies. This means journalists and researchers must gather the data from a variety of incomplete and often contradictory sources, a resource-intensive and time-consuming process.

At the same time, understanding how and why these other immigration enforcement-related deaths occur illustrates the vast reach of immigration enforcement in American society, which is deeply entwined with policing, jails, prisons, and other forms of carceral control.

ICE Detainers

ICE issues thousands of “detainer requests” each year. These requests ask prisons and jails to hold people past their official release dates, allowing ICE to arrest them directly upon their release from custody. Those who died while being held on these detainers at a state prison or county jail might still be alive if their exposure to carceral conditions had not been prolonged. 

However, we were unable to include these deaths in our database for the simple reason that ICE is not required to track or report them. Data on these deaths must be obtained from the state, county, or federal agency overseeing the death location. Complicating matters further, mortality data from these facilities rarely indicates whether someone was being held on an ICE detainer at the time of their death. Some of these deaths are likely reflected in our database of deaths in prison, but we have no way to know the immigration status of the people who died in these facilities.  

Arrest-Related Deaths 

Under the Death in Custody Reporting Act, deaths that occur during an arrest are considered deaths in custody. However, in order to maintain consistency with the Project’s focus on incarceration, we focused here only on deaths occurring in ICE detention. 

Establishing this parameter meant we excluded from our ICE death data the recent high-profile killing of Renée Good by ICE agents. (Alex Pretti, another person killed by immigration agents this year, was shot by CBP agents, not ICE agents.) Still, it bears noting that, before last year, deaths during ICE arrests were exceedingly rare—not a single person died during an ICE arrest between 2016 and 2024. Since January 2025, at least three ICE arrests have resulted in deaths (including Good). 

Post-Release Deaths 

It is particularly difficult to track deaths occurring shortly after release because of a medical emergency or inadequate healthcare while in detention.   

We know these deaths happen. Johana Medina Leon died in June 2019, four days after  

ICE “paroled” her while she was in critical condition in a New Mexico hospital. The Los Angeles Times uncovered emails showing that ICE staff expedited her release after discovering that she was seriously ill. The LA Times investigation further documented at least seven post-release deaths from ICE detention nationally between 2017 and 2022, including at least one other person who was on life support when ICE processed his release. In one high-profile incident earlier this year, a nearly blind refugee from Myanmar died days after CBP agents released him in the middle of the night outside a donut shop in Buffalo, New York; in April, the local medical examiner ruled the death a homicide.  

Congress does not require ICE to report these deaths, making it nearly impossible to quantify how often they occur. Post-release deaths are a persistent issue for tracking detention-related deaths more broadly. In Pennsylvania, for instance, a statewide investigation of jail deaths uncovered dozens of cases in which jails released individuals shortly before they passed away from illnesses or injuries experienced during their incarceration, and an investigation by ProPublica and AL.com showed Alabama sheriffs frequently release people from custody to avoid paying their medical bills.  

Moreover, deportation itself can be fatal. Despite laws and international treaties that prohibit expelling people to countries where they face a significant risk of death, torture, or permanent injury, the United States deports thousands of asylum seekers and refugees to unsafe destinations each year. Their fates are often a mystery—no U.S. government agency or international body tracks post-deportation deaths on a systematic basis. Human rights advocates, journalists, and researchers have stepped up, documenting hundreds of these deaths. In El Salvador alone, Human Rights Watch found more than 100 people who died violent deaths between 2013 and 2020 after being deported from the United States. 

Since 2025, the Department of Homeland Security has weakened many protections meant to prevent these deaths. For example, the Trump administration’s decision to revoke Temporary Protected Status (TPS) for people from 13 countries put nearly a million people at risk of deportation to societies experiencing significant conflict or civil unrest. The Trump administration has also deported at least 300 people to so-called “third countries” that agreed to accept deported people regardless of their country of origin. Several of them—including Eswatini, Equatorial Guinea, and South Sudan—routinely commit documented human rights abuses, and have confined deported migrants in unsanitary, makeshift detention centers. 

Deaths in CBP Custody

For most of ICE’s history, deaths in CBP custody have far exceeded deaths in ICE custody. Many of these deaths are related to medical emergencies experienced while people cross the border, but others are caused by inadequate medical care while in detention, vehicle accidents, and use of force by CBP agents. According to a database maintained by the ACLU of Texas, since 2010, at least 367 people, including 78 children, have had fatal encounters with Border Patrol. 

Reports by congressional investigators and the DHS Inspector General have found that Border Patrol agents often fail to perform mandatory medical screenings of detained migrants. When medical emergencies occur, there are frequently critical delays in transporting patients to hospitals. Like ICE detention facilities, CBP lockups face chronic understaffing and rely on contract medical providers incentivized to minimize costs at the expense of patient care. A 2020 report by the Government Accountability Office found that CBP had misspent more than $125 million budgeted for medical expenses on purchasing new vehicles, weapons, and tactical gear. 

Additionally, on-duty Border Patrol agents have killed at least 75 people since 2010, including teenagers as young as 16 years old and several U.S. citizens. Fatal use of force by Border Patrol agents rarely results in discipline or criminal liability, and the Supreme Court has limited the ability to file civil lawsuits against Border Patrol agents who shoot and kill. Further identification and examination of fatalities in Border Patrol custody is crucial and worthy of attention quite apart from deaths in ICE-related fatalities. 

Deaths on the Border

Migration itself can be a deadly undertaking. According to the United Nations International Organization for Migration (IOM), at least 6,667 people have died attempting to cross the U.S.-Mexico border since 2014. This figure is almost certainly a significant undercount. 

The lethality of the US-Mexico border is by design. Since the Clinton administration, U.S. authorities have pursued a  “prevention by deterrence” strategy to intentionally impede migration by funneling crossings into more remote, hazardous terrain. 

Border “encounters”—the official term used by Border Patrol for apprehensions of migrants during border crossing—spiked during the Biden administration to a high of 2.2 million in 2022, then fell sharply following Trump’s 2025 inauguration to 237,538 in 2025. IOM reported 1,528 deaths at the US-Mexico border in 2022, roughly one death for every 1,440 encounters with Border Patrol. In 2025, the organization reported 409 deaths, or roughly one death for every 581 crossings. Although apprehensions are an imperfect proxy for crossings, the data suggests that the risk of dying during border crossings has increased under the second Trump administration, though fewer crossings have meant fewer deaths overall.

Work still to be done

The dataset of deaths in ICE detention published by the UCLA Law Behind Bars Data Project is the most comprehensive publicly available database of its kind. But the deaths it includes represent only a portion of the total deaths caused by U.S. immigration enforcement. We hope that future data collection by researchers and journalists will help paint a more comprehensive picture of these deadly consequences. At a minimum, every person who dies as a result of immigration enforcement deserves to be counted.