On June 28, Sister Leticia “Letty” Ugboaja, a Catholic nun from Nigeria, was arrested by U.S. Immigration and Customs Enforcement (ICE) agents while walking to Sunday mass in McAllen, Texas. Agents reportedly handcuffed the 56-year-old, took her to a detention facility, confiscated her rosary, and did not provide her prescribed medication. She was released hours later without explanation. According to her diocese, Sister Ugboaja had worked as a registered nurse in the area for approximately ten years and had entered the country legally.
This incident is indicative of a broader trend over the past year, where stringent federal immigration enforcement appears to be clashing with religious liberty and freedom of worship. While President Donald Trump’s administration has pursued a hardline approach to immigration, reports have surfaced of federal agents detaining and harassing clergy and religious workers across various denominations, including Catholic, Protestant, and Muslim faiths. These actions have reportedly caused fear within religious communities, many of which have been involved in organizing responses to immigration crackdowns.
The Department of Homeland Security and ICE have not provided immediate comment on Sister Ugboaja's case or other religious liberty concerns raised by rights groups. Similar incidents have been reported nationwide. In November, an Episcopal bishop in Texas reported the detention of a Kenyan priest who worked legally for the Texas Department of Criminal Justice. In July 2025, a Muslim hospital chaplain in Ohio, an Egyptian immigrant, was detained for weeks following an immigration check-in. Earlier this year, Cardinal Blase Cupich of Chicago reported that priests in his archdiocese were stopped by federal agents and asked to prove their citizenship. Clergy have also faced pepper spray and tear gas at anti-ICE protests.
Shifting Policies on Sensitive Locations
For years, federal immigration enforcement operated under “sensitive location” guidelines that protected places such as hospitals, schools, and churches from enforcement actions. These guidelines, first formalized during the Obama administration and maintained through the first Trump administration and the Biden presidency, had some form of protection for houses of worship for over three decades, according to the legal organization Democracy Forward. However, the Department of Homeland Security rescinded these rules at the start of the second Trump administration. A DHS statement at the time indicated the move was intended to "empower" Customs and Border Protection (CBP) and ICE to arrest individuals who were "hiding in America’s schools and churches." This policy change prompted legal challenges from immigrant rights and religious freedom organizations.
Bradley Girard, senior counsel at Democracy Forward, stated earlier this year that targeting individuals at houses of worship violates religious freedom and harms communities. He argued that the policy is unlawful and dangerous, chilling religious exercise and undermining public safety by driving people into the shadows. While some legal suits have resulted in judicial protections for specific religious institutions facing immigration raids, broader federal protections for places of worship have not been formalized.
Legal Battles Over Pastoral Care
Churches, religious organizations, and legal aid groups have engaged in piecemeal legal battles to secure religious liberty protections, particularly concerning pastoral care, which includes counseling, sacraments, and religious rituals. In Minneapolis, Groundwork Legal sued ICE over a ban on clergy access to the Bishop Henry Whipple Federal Building. Irina Vaynerman, co-founder and lead attorney at Groundwork Legal, explained that federal law requires the government to limit religious practice only through the least restrictive means possible. A categorical ban on clergy access, she argued, did not meet this standard.
Groundwork Legal filed its suit in February on behalf of multi-denominational faith organizations and leaders, citing the Religious Freedom Restoration Act and the First Amendment. In March, a judge issued a preliminary injunction ordering the federal government to allow faith leaders to offer pastoral care to individuals held by ICE at the building. A similar lawsuit was filed last fall in Illinois after ICE and CBP officials denied clergy access to the Broadview federal center, preventing them from ministering to detainees, including offering Communion. A judge granted a partial victory, ordering agents to allow clergy access for Ash Wednesday services, and in May, ICE and religious leaders reached an agreement for daily visits while litigation continues.
Vaynerman noted that these agreements are temporary reprieves, as no national protections or guarantees have been established beyond these specific legal actions. She emphasized the importance of the government recognizing and facilitating constitutionally required access for pastoral care, especially for individuals enduring difficult circumstances.