The federal government’s current heightened focus on arresting and deporting undocumented immigrants has turned courthouses in New York State and across the country into places where criminal law practitioners “face off” against immigration law enforcers. Although Immigration and Customs Enforcement (ICE) officials are prohibited from making arrests inside courtrooms, they are permitted to do so in hallways and directly outside courthouses. The prevalence of ICE agents, often in plain clothes, making arrests has reportedly made many immigrants afraid to appear in court as defendants or witnesses.