In a crowded street scene, two people hold a large white banner with blue letters that reads "El Pueblo Unido/Defenderá a las Familias Migrantes!" One of the people holding the banner is out of frame, but the one on the right is a young white woman with dark hair end eyeglasses. In front of the banner is a young dark-haired man in a yellow T-shirt holding a megaphone to his mouth. Several other people are visible in the crowd. A partly visible sign behind the banner reads "Jamas Será Vencido!"

HUD

HUD’s Cooperation with ICE Stokes Fear in Immigrant Communities

Home is no longer a safe space for thousands of families who live with someone who's undocumented. Caught between housing assistance and ICE surveillance, many are forced to be silent—or self-evict.

One of many protests against ICE in Chicago on June 10, 2025. Photo by Flickr user Paul Goyette, CC BY 2.0

https://www.flickr.com/photos/pgoyette/54581932663/in/photostream/

updated july 23

Most weeks for the last several months, Frida* has sent her 20-year-old daughter to the grocery store to pick up what they need. It’s not an ideal arrangement, but Frida doesn’t leave the house much these days—mostly just to work her longtime retail job. Every time she goes out, her kids worry. “They say, ‘Mom, be careful. Remember la migra is around.’” Frida’s three youngest, ages 6, 18, and 20, are United States citizens; the older two, 25 and 27, were born in Mexico and lack legal documentation, like Frida. All five kids live under the same daily tension she does. Even her youngest has internalized the threat. “He told me his friend said Mexicans can’t go to Sam’s Club.” (*Frida is a pseudonym. She spoke with me through an interpreter.)

In her 23 years in the U.S., Frida says, Immigration and Customs Enforcement (ICE) agents have never been as aggressive they’ve become since the Trump administration began mass arrests and deportations in early 2025. It’s made it difficult to conduct daily life—even going grocery shopping. She’s grateful for her job, where she feels mostly safe. Her income pays the $1,200 in rent (plus utilities) she’s responsible for each month at her three-bedroom apartment in a quiet, mostly white apartment complex in Fort Collins, Colorado. Market-rate rent for her unit is $2,500 per month, but her Section 8 housing voucher—which she spent a decade on a waiting list to receive—restricts the amount she pays to a program-designated portion of her income, based on her family’s eligibility; the federal government pays the remainder.

A young man in a black mask and with a red scarf wrapped around his head leans on a large bin (recycling or trash) on which someone has written in pink chalk: "We love our immigrant neighbors."
A protest was held at the Federal Detention Center in Philadelphia on June 10, 2025, after ICE agents kidnapped five people in South Philly. Photo by Flickr user Joe Piette, CC-BY-NC-SA-2.0

Frida’s family qualifies for a voucher because her youngest son meets the program eligibility requirements outlined in Section 214 of the Housing and Community Development Act, which allows families to receive federal assistance if at least one household member is a U.S. citizen or can prove their legal immigration status. The law allows ineligible family members to live in the unit without declaring their immigration status or providing any documentation. This means they’re counted toward household size and are considered occupants, but the assistance is prorated to exclude them. Under this law families can stay together and the undocumented members choose not to “contend” (i.e., claim) eligibility; the family as a whole receives a reduced subsidy based solely on eligible members.

But Frida’s voucher, like everything else these days, feels precarious. “I feel like it’s a privilege,” she says. “But I also always feel a little worried because I have to preserve it.”

So Frida lives carefully, quietly. She immediately completes and returns every housing document she gets, whether from the property management or the public housing authority (PHA) that administers the local Housing Choice Voucher program, afraid even a small mistake will get it taken away or draw attention from her landlord—or, worse, from ICE. She avoids her neighbors, worried they’re watching for a reason to complain. “I’m always in suspense,” she says. “Because anything that can happen will affect me. I’ll be without a house, and how am I going to get another house for my children?”

Whiplash Enforcement: No Safety in the Mixed Signals

The same quiet fear and isolation that are weighing so heavily on Frida and her family have become constant stressors in immigrant communities across the U.S. since Trump took office.

The federal crackdown started heavy: ICE ramped up arrests dramatically to meet a new 3,000-per-day arrest quota issued by the Department of Homeland Security (DHS), which administers ICE activities. Then Trump issued a lukewarm call for a pullback on mass arrests at hotels, farms, and construction sites, saying they were hurting “American” businesses. DHS largely ignored that request, publicly stating that its immigration policy hadn’t changed. In the weeks since, ICE has escalated arrests in dramatic, intimidating ways, sending masked agents in unmarked vans and on horseback through public parks, for example. They have been detaining primarily people with no criminal records, many people who do have legal status, and even U.S. citizens. Raids have continued, including a recent raid at a California cannabis farm that resulted in the death of one farmworker. And with the recent passage of Trump’s sweeping tax-and-spend legislation, ICE got a 250 percent hike in its annual budget—making it the most expensive federally funded law enforcement agency. These activities have sown terror and confusion while largely reinforcing what many immigrant families already knew: The rhetoric may shift, but the threat is always there.

“For Hispanic communities, there’s no confusion. We know that they are going after us, so we just don’t trust. We just assume that they’re coming, and we’ve been correct,” says Monica Henao, who’s worked at the Northern Colorado-based immigration rights organization Alianza Norco for more than 20 years. “We see people sending videos of ICE everywhere—every single day, all the time, they send videos with ICE activity all over the place. So we know.”

Even Henao’s U.S.-born adult son avoids going out. “He’s so scared to drive to places. We’re not going outside. We’re not going to the restaurants. We’re not going to concerts. That’s how bad it is,” she says. “It’s affecting us all—the whole Hispanic community—in every single way, even in our own apartments, all the time.”

HUD + DHS: When Your Home Doesn’t Feel Safe

That fear has reached into the most essential domain of all: housing.

The U.S. Department of Housing and Urban Development (HUD) and DHS in March issued a joint memorandum of understanding (MOU): American Housing Programs for American Citizens. Though it didn’t change existing housing law, the MOU allowed HUD to begin sharing information with DHS about the immigration status of household members in federally assisted housing—even if those family members had explicitly declined federal benefits.

The move raised immediate alarm among housing and immigrant rights advocates. The data-sharing agreement allows DHS to identify individuals without legal status living in public housing—not because they’re receiving benefits, but simply because they live with someone who is. Legal experts warn it could be used to build cases for future disqualification or deportation.

While the MOU hasn’t yet resulted in any formal policy change, the damage is already visible. Families like Frida’s who waited years for housing vouchers are now terrified that a clerical error, a background check, or a nosy neighbor could bring DHS to their door. Some skip recertification appointments. Others quietly move out. What results is not a formal eviction—but a chilling, slow-motion exit from public housing that HUD will never have to report.

[RELATED ARTICLE: ICE is Coming to Your Building—Are You Ready?]

At the National Housing Law Project (NHLP), a national housing justice nonprofit, staff are working to balance two realities: widespread fear among immigrant families—and the frustrating lack of clarity coming from HUD and DHS. “We’ve seen this administration act cruelly and carelessly in carrying out its immigration agenda,” says Marie Claire Tran-Leung, NHLP’s evictions initiative project director. “And the carelessness is really clear in the MOU.” It’s written so vaguely that NHLP attorneys don’t even consider it legally binding. “It reads more like a political statement than a policy,” Tran-Leung says. “It’s imprecise, and it’s very hard to pin the administration down on what they’re actually doing, or what type of information is being shared.” And that vagueness is its own kind of cruelty—leaving families to imagine the worst and housing advocates scrambling to verify what’s rumor and what’s real.

So far, NHLP hasn’t documented any confirmed cases of ICE showing up at public housing authorities as a direct result of the MOU. But that doesn’t mean families aren’t already being harmed. “We’re deeply concerned that immigrant families may preemptively leave housing—even when they have the legal right to stay—because of misinformation or fear,” Tran-Lueng says.

One particularly damaging misconception is the way the MOU and accompanying press materials conflate mixed-status families and undocumented residents. That’s both factually wrong and legally dangerous, considering the Section 214 provision excluding family members who aren’t receiving benefits from providing any information about their immigration status. “One of the things we’ve been trying to get the message out around for members within mixed-status families is that if you choose not to contend eligibility, you do not have to turn over any sort of documentation to the PHA,” she says. “There may be changes to that coming down the road, but right now, legally, you don’t have to provide any sort of information.” While the law is clear about what information does and does not need to be shared, without clear guidance from HUD about current enforcement practices, advocates worry that some housing authorities or landlords could overreact to political pressure, putting families at greater risk.

Tran-Leung says PHAs should educate themselves and their staff on what to do if ICE shows up, including how to best protect residents and how to get the message to tenants that they have rights. “That’s a really powerful thing that PHAs can do, because, frankly, I don’t think all tenants see the difference between HUD headquarters and a PHA, and hearing something from the PHA is very, very powerful during this time in terms of protecting confidentiality,” she says, adding that PHAs should refrain from asking for more information from tenants than is necessary, and stresses that there’s nothing in the law that says PHAs or landlords must keep records of family members’ legal status.

Fear-Driven Displacement: Pushed Out, Not Evicted

Frida hasn’t missed a form. She doesn’t violate her lease. Her rent check is always on time. And yet, she worries her family’s stability could be yanked out from under her at any moment. Remaining on high alert for ICE is a constant stress, but it’s often the microaggressions that get to her the most. Some of them are frightening—like recently when she was with her son and an older white man made gun shapes with his hands and pointed at them, imitating shooting gestures.

Others are simply maddening. She didn’t, for example, feel she could contest a $300 jump in her carpet cleaning fee this year—up from $39 last year. The property management company cleans carpets throughout the complex annually, so Frida knew the appointment was coming and made sure her house was spotless. The carpet had no stains or damage. When she got the $339 bill, management blamed the upcharge on the fact that she has dogs—even though she also had them last year and they’re never in the only carpeted area, which is upstairs. “It makes me think they’re just making excuses,” she says. “But I feel like, do I pay them to not get into an ordeal where they might be able to kick me out, or do I tell them I don’t want to pay because the guy only took 20 minutes?”

Situations like this are what push many families in Frida’s situation toward de facto eviction—when the eviction doesn’t go on paper, because it doesn’t need to. When a low-income renter who lacks legal status is so terrified of drawing attention that she’ll scrimp on other necessities to come up with the $300 to pay the upcharge. When the price of asking a question or asserting your rights feels higher than your rent.

Housing attorneys and tenant advocates have a name for this: “constructive eviction.” That’s when a landlord or PHA deliberately impedes upon or hampers a tenant’s “peaceful enjoyment of the premises” to the point where the tenant has no other option but to vacate. In these cases, no one files a formal notice to vacate; residents leave due to fear, harassment, or unbearable conditions. And for undocumented tenants or members of mixed-status families, that fear is more than a feeling—it’s a rational response to a system that’s built to punish them for existing.

Displaced by Dread

There’s data to back up anecdotal stories of fear and harassment. A 2023 Urban Institute report found that nearly one in four adults in mixed-status families avoided accessing noncash benefits like SNAP (i.e., food stamps), Medicaid, or housing assistance—even when they were eligible—because they feared it could negatively affect their immigration status. Families with children also suffer: one in four mixed-status families with kids avoided programs designed to help them stay fed, housed, or healthy. And it’s not because they didn’t need the help. The same report found that more than 60 percent of adults in mixed-status families experienced serious hardship, including food insecurity, untreated medical issues, or trouble paying for rent and utilities. In other words: families aren’t opting out of these programs because they’re comfortable; they’re opting out because they’re scared. And it’s putting kids, especially, at risk.

HUD’s own internal analysis projected that mixed-status families would leave HUD-assisted housing en masse—not because of formal evictions, but out of fear. In an April 2019 regulatory impact assessment, HUD estimated that “most mixed households will leave HUD’s assisted housing as a result of this rule.” HUD didn’t hide its expectations—it predicted that most mixed-status families would simply self-exit, divide their households, or ask undocumented family members to vacate to retain their housing assistance—effectively reducing program participation without any official removal action. HUD also quantified the impact: those departures would affect approximately 25,000 mixed-status households (around 100,000 individuals) receiving vouchers, public housing, or project-based Section 8.

Even without new rules, advocates warn that the precedent set by HUD’s own modeling—and the uncertainty it creates—will successfully pressure families to self-disqualify. Housing rights advocates are sounding the alarm. In a March statement, the Alliance for Housing Justice—a national network of legal and grassroots organizations including the National Housing Law Project, PolicyLink, and the Poverty & Race Research Action Council—warned that the HUD–DHS MOU is “aimed at surveilling and intimidating mixed-status families.” Rather than address the nation’s housing crisis, the Alliance wrote, HUD is choosing to “discourage and disqualify eligible, rent-paying residents from programs they have a right to access.”

Staying Silent to Stay Housed

For families like Frida’s, the fear doesn’t just creep in when it’s time to recertify—it’s in her kids’ voices when they remind her to be careful before she leaves the house, in the text chains within her Hispanic community warning one another to stay inside because ICE was spotted nearby, in the glances from her neighbors she can’t quite interpret. “I live in a very white neighborhood,” she says. “And I feel like all my neighbors are kind of watching us to see what happens. I worry they could be complaining about us.”

I feel like all my neighbors are kind of watching us to see what happens. I worry they could be complaining about us.”

In her living room, Frida keeps the curtains half‑drawn. She’s always on edge, and feels like her kids are, too. If someone comes to the door, her daughter answers it, ready to deflect questions—a heavy burden to place on a 20-year-old. Frida’s phone pings often with flurries of messages: ICE sightings, rumors, and speculation about where they’re going to be next. She recently learned that people attending a housing rights meeting at a local mobile home park scattered early because ICE was seen in the area, again.

Like so many immigrant families, Frida and her kids will remain hunkered down, weathering the uncertainty and fear. After five years in the same apartment, it’s home—the only one her youngest has known. Besides, moving would mean risking her voucher, and losing it would likely mean facing homelessness.

This is the silent, hidden crisis no one is tracking. No court filings. No lockouts. No paper trail. Just families quietly disappearing from the safety nets they’re legally entitled to—either displaced by dread instead of due process or staying silent to preserve their ability to stay out of ICE’s sight.

And unless policymakers reinstall the firewall between HUD and DHS, the fear, and the resulting self-evictions and self-imposed house arrests, will keep redrawing the rules around who gets to feel safe at home, and quietly clearing out people our housing system was built to protect.

Editor’s Note: This article has been edited to correctly identify National Housing Law Project as a member of the Alliance for Housing Justice.

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