CREATORS: When Can an ICE Agent Shoot Into A Moving Vehicle?

 Matthew T. Mangino
CREATORS
January 13, 2026

On Jan. 7, 2026, Renee Nicole Good was fatally shot by an Immigration and Customs Enforcement agent in Minneapolis, Minn. The shooting occurred during an ICE enforcement operation and has sparked nationwide protests.

In the moments before the shooting, Good is heard telling the agent that she wasn't mad at him, and the agent, identified as Jonathan Ross, began to circle her vehicle. She backs up her vehicle as Ross crosses in front of her, then she slowly begins to move forward and turns to the right. Ross is near her left headlight when he fires three shots into the vehicle, killing Good.

According to The New York Times, in the last four months, immigration officers have fired on at least nine people in five states and Washington, D.C. All of the individuals targeted in those shootings were, like Good, fired on while in their vehicles.

The pattern raises serious concerns. According to Reason Magazine, for decades, police officers have been trained not to shoot at moving vehicles. New York City's police department banned firing at unarmed drivers in 1972. After it did so, police shootings plummeted in the city. The country's 25 largest police departments generally prohibit firing at vehicles, according to the Times.

Seth Stoughton, a former police officer and current professor of criminal justice at the University of South Carolina, told Reason, "First, we need to keep in mind the legal rules that justify shooting at all ... officers can use deadly force when the subject is reasonably perceived as presenting an imminent threat of death or great bodily harm."

"So, at a very big picture level, we have to answer the question of: Did the officer reasonably perceive an imminent threat of death or great bodily harm? If the answer is no, there shouldn't be a shooting," continued Stoughton.

According to Reuters, there is no universal law enforcement training standard for firing into vehicles. But most police departments and federal policy bar shooting at a moving vehicle unless the driver poses an imminent threat of deadly force beyond the car itself.

Experts say firing at a moving car is one of the riskiest forms of lethal force, increasing the chance of stray gunfire or a loss of vehicle control that can endanger innocent bystanders. Why not just move away from the vehicle? Justice Department policy says deadly force is allowed only when no reasonable alternative exists, including stepping out of the vehicle's path.

The law has long been that police officers cannot use deadly force solely to arrest someone or to disable a fleeing vehicle if the person does not pose an immediate threat. According to The Associated Press, federal law enforcement officers operate under similar guidance.

The operating manual of the Department of Justice mandates that firearms should not be used simply to disable a moving vehicle. The policy allows deadly force only in limited circumstances, such as when someone in the vehicle is threatening another person with deadly force or when the vehicle itself is being used in a way that poses an imminent risk and no reasonable alternative exists but deadly force.

In the wake of Good's killing, President Donald Trump was asked if he believed deadly force was necessary in this case. His response: "It was highly disrespectful of law enforcement. The woman and her friend were highly disrespectful of law enforcement."

Vanita Gupta, a former associate attorney general who oversaw both the civil rights division that can prosecute federal agents and the civil division that defends them, told The New York Times, "Being 'disrespectful' does not warrant the use of deadly force."

Matthew T. Mangino is of counsel with Luxenberg, Garbett, Kelly & George P.C. His book The Executioner's Toll, 2010, was released by McFarland Publishing. You can reach him at www.mattmangino.com and follow him on Twitter @MatthewTMangino

On Jan. 7, 2026, Renee Nicole Good was fatally shot by an Immigration and Customs Enforcement agent in Minneapolis, Minn. The shooting occurred during an ICE enforcement operation and has sparked nationwide protests.

In the moments before the shooting, Good is heard telling the agent that she wasn't mad at him, and the agent, identified as Jonathan Ross, began to circle her vehicle. She backs up her vehicle as Ross crosses in front of her, then she slowly begins to move forward and turns to the right. Ross is near her left headlight when he fires three shots into the vehicle, killing Good.

According to The New York Times, in the last four months, immigration officers have fired on at least nine people in five states and Washington, D.C. All of the individuals targeted in those shootings were, like Good, fired on while in their vehicles.

The pattern raises serious concerns. According to Reason Magazine, for decades, police officers have been trained not to shoot at moving vehicles. New York City's police department banned firing at unarmed drivers in 1972. After it did so, police shootings plummeted in the city. The country's 25 largest police departments generally prohibit firing at vehicles, according to the Times.

Seth Stoughton, a former police officer and current professor of criminal justice at the University of South Carolina, told Reason, "First, we need to keep in mind the legal rules that justify shooting at all ... officers can use deadly force when the subject is reasonably perceived as presenting an imminent threat of death or great bodily harm."

"So, at a very big picture level, we have to answer the question of: Did the officer reasonably perceive an imminent threat of death or great bodily harm? If the answer is no, there shouldn't be a shooting," continued Stoughton.

According to Reuters, there is no universal law enforcement training standard for firing into vehicles. But most police departments and federal policy bar shooting at a moving vehicle unless the driver poses an imminent threat of deadly force beyond the car itself.

Experts say firing at a moving car is one of the riskiest forms of lethal force, increasing the chance of stray gunfire or a loss of vehicle control that can endanger innocent bystanders. Why not just move away from the vehicle? Justice Department policy says deadly force is allowed only when no reasonable alternative exists, including stepping out of the vehicle's path.

The law has long been that police officers cannot use deadly force solely to arrest someone or to disable a fleeing vehicle if the person does not pose an immediate threat. According to The Associated Press, federal law enforcement officers operate under similar guidance.

The operating manual of the Department of Justice mandates that firearms should not be used simply to disable a moving vehicle. The policy allows deadly force only in limited circumstances, such as when someone in the vehicle is threatening another person with deadly force or when the vehicle itself is being used in a way that poses an imminent risk and no reasonable alternative exists but deadly force.

In the wake of Good's killing, President Donald Trump was asked if he believed deadly force was necessary in this case. His response: "It was highly disrespectful of law enforcement. The woman and her friend were highly disrespectful of law enforcement."

Vanita Gupta, a former associate attorney general who oversaw both the civil rights division that can prosecute federal agents and the civil division that defends them, told The New York Times, "Being 'disrespectful' does not warrant the use of deadly force."

Matthew T. Mangino is of counsel with Luxenberg, Garbett, Kelly & George P.C. His book The Executioner's Toll, 2010, was released by McFarland Publishing. You can reach him at www.mattmangino.com and follow him on Twitter @MatthewTMangino

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