Federal immigration investigators examined at least 82 nonprofit organizations in Pennsylvania and 41 in New Jersey while searching for evidence of illegal voter registration. In New Jersey, their review found no derogatory information about any of the organizations examined.
The investigators also considered using undercover agents to approach organizations suspected of helping noncitizens register to vote.
Those details appeared in 166 pages of internal government records released October 7 by Democracy Forward, a legal advocacy organization that obtained them through the Freedom of Information Act.
The records show something worth examining closely. Federal investigators weren’t limiting their work to people suspected of registering or voting illegally. They were also looking at organizations involved in helping people participate in elections.
The investigation expanded beyond individual voters
The records describe an extensive operation by Homeland Security Investigations, Immigration and Customs Enforcement’s investigative division.
By June 1, investigators had received about 50.6 million records from the Justice Department and another 48.4 million from what officials described as independent sources.
Heather Honey, a senior adviser involved in the administration’s election investigations, provided those records. The documents don’t identify all the independent sources.
These numbers represent records collected for analysis, not confirmed cases of illegal voting. They also shouldn’t be mistaken for counts of separate individuals.
Investigators compared voter information with other government data, developed leads, and examined organizations they believed might be connected to unlawful registration.
One internal document described a shift toward a “network-based investigative approach.” Instead of focusing on individual cases, investigators examined organizations and people they suspected of helping others violate voting laws.
In Pennsylvania, that examination included the state chapter of the Council on American-Islamic Relations and the clothing retailer Zumiez, which had previously participated in voter-registration initiatives. Both were flagged for additional investigation.
The documents don’t establish that either organization committed a crime.
Then investigators considered going undercover
By late May, HSI and the FBI were developing investigative plans involving seven Ohio companies associated with Black Fork Strategies, a progressive canvassing firm.
Federal investigators alleged connections between the firm and several noncitizens registered to vote in Cuyahoga County.
On June 8, ICE informed senior officials that agents planned to execute federal search warrants and interview more than 100 current and former employees. Three days later, federal agents raided the Ohio Organizing Collaborative, a progressive organization connected to Black Fork Strategies.
The released documents are heavily redacted and don’t establish that Black Fork itself was the target of the planned warrants. The raid also doesn’t establish that the organization committed wrongdoing.
Other investigations went nowhere.
Investigators reported finding no adverse information about the 41 New Jersey organizations they reviewed. A separate nonprofit examination found no suspicious financial activity, and an Ohio inquiry was closed after investigators exhausted their leads.
Even so, an internal June report discussed the possibility of undercover agents approaching organizations suspected of recruiting noncitizens to register illegally. The report identified New Jersey and Pennsylvania as priorities.
The released records don’t establish that those undercover operations took place.
That distinction matters. Investigators considered the tactic, but considering an operation isn’t the same as carrying it out.
The concern isn’t investigating voter fraud
Noncitizens generally cannot vote in federal elections. Knowingly helping someone register or vote illegally can also violate federal law.
The federal government has legitimate authority to investigate suspected crimes. If agents have evidence that an organization is knowingly registering ineligible voters, they can investigate.
The Department of Homeland Security says its efforts aim to identify noncitizens who vote illegally, prosecute violations, and protect eligible citizens’ votes.
The newly released records don’t prove that every investigation was improper or that the administration deliberately intended to intimidate voters.
But they do establish that investigators expanded their attention from suspected individual violations to organizations involved in voter registration, including organizations for which their reviews found no adverse information.
That raises a different question.
Was each organization selected because investigators had credible information connecting it to a violation? Or were investigators examining organizations first, hoping their searches would uncover something incriminating?
The records don’t answer that question for every organization.
They do show why the answer matters.
A government investigation can put an independent organization under pressure
One of the Seven Patterns of Power is Attack Independent Institutions.
It describes situations in which government authority weakens, punishes, or interferes with organizations that are supposed to operate independently of those holding political power.
A voter-registration organization doesn’t work for the president. It doesn’t need the president’s permission to encourage eligible citizens to register.
And it shouldn’t face government punishment merely because officials dislike its work or the voters it reaches.
Federal investigators have powers that those organizations don’t. They can collect information, conduct surveillance, seek search warrants, and refer suspected violations for prosecution.
Those powers are legitimate when exercised within the law and supported by appropriate evidence.
They can also place enormous pressure on an organization.
A search warrant can interrupt an organization’s operations. Investigative demands can consume staff time and legal resources.
Public knowledge that an organization is under federal investigation can damage its reputation, even if investigators eventually find no wrongdoing.
None of that requires an organization to be convicted of a crime.
The danger begins when helping people exercise a lawful civic right becomes a reason for broad government scrutiny rather than when credible evidence identifies a particular violation.
The ICE records don’t establish that every organization faced that kind of pressure. But they show investigators adopting an approach that can expose civic organizations to it.
That is what makes this development an example of the Pattern worth watching.
Kentucky has already shown where a demand for voter information can be challenged
Kentucky has faced a related dispute over the federal government’s effort to obtain voter-registration information.
In August 2025, the Justice Department demanded Kentucky’s complete voter-registration list, including personal information such as dates of birth, driver’s license numbers and portions of Social Security numbers.
Secretary of State Michael Adams and the Kentucky State Board of Elections resisted releasing the sensitive information. Kentucky provided a redacted list but declined to release the unredacted records the department requested.
The Justice Department sued in February 2026.
Several organizations and individuals, including the League of Women Voters of Kentucky, sought to participate in the case because they were concerned about the disclosure of voters’ personal information. The court permitted their intervention.
On July 23, U.S. District Judge Claria Horn Boom dismissed the Justice Department’s lawsuit and denied its request to compel production of the records.
The Justice Department appealed the next day.
The Kentucky ruling doesn’t decide whether ICE’s investigations of voter-registration organizations are lawful. Nor does the newly released evidence establish that Kentucky organizations were among those investigated.
The cases concern different government actions.
But Kentucky’s experience shows something important about where government power can be challenged.
State officials declined a federal demand. Organizations representing voters entered the lawsuit. A judge examined the government’s claimed legal authority and ruled against it.
The administration couldn’t obtain the disputed information simply by insisting that it was entitled to it.
That decision remains subject to appeal.
Who can stop an investigation that goes too far?
The investigators themselves have the first opportunity.
If an examination produces no evidence of wrongdoing, officials can close it rather than continue looking for a case. The released records show that investigators did close at least one Ohio inquiry after exhausting their leads.
That’s an important safeguard because criminal investigations should follow the evidence.
Courts provide another limit. Federal agents seeking judicial search warrants must satisfy legal requirements, including probable cause. A judge can deny a warrant application that fails to meet the required standard.
Kentucky’s voter-data case illustrates how courts can also reject federal demands when the government cannot establish the authority it claims.
Another institution plays a role here: Congress.
The House Committee on Homeland Security oversees the Department of Homeland Security, including ICE. It has already held an oversight hearing involving ICE leadership this year.
Committee members can demand explanations from agency officials, examine records and call witnesses to testify.
The newly released documents give them specific questions to pursue.
What evidence caused investigators to select particular voter-registration organizations? Did investigators clear organizations when they found no adverse information? Who authorized the proposed undercover operations, and did they actually conduct any?
Those questions concern how federal investigators used their authority, not whether noncitizens should be allowed to vote.
So what can an ordinary person do?
An ordinary voter cannot order ICE to close an investigation. And someone with no connection to an investigation is unlikely to know what evidence agents are reviewing.
But the House Homeland Security Committee can examine ICE’s conduct.
Kentuckians can ask their U.S. House representative to push the committee to hold an oversight hearing focused on these records. They can point to the specific findings about nonprofit reviews and proposed undercover operations and ask for public answers.
A representative who doesn’t sit on the committee cannot force its leadership to hold a hearing. Committee leaders decide whether to act, and congressional scrutiny doesn’t automatically end an investigation.
Still, an oversight hearing could require agency officials to explain why they selected the organizations and what happened when investigators found no evidence of wrongdoing.
For voter-registration organizations themselves, the immediate question is different.
If federal agents approach an organization or demand its records, its leadership can consult legal counsel, determine what authority the agents are exercising, and decide whether to challenge the demand in court.
Legal options depend on what investigators have requested or obtained.
There is also a lesson in how the public learned about this operation.
Democracy Forward used federal records law and litigation to obtain documents that revealed what investigators were doing. Those records let people compare the government’s stated objectives with its actual investigative activity.
The documents don’t settle whether the investigations were lawful. They make the government’s actions available for scrutiny.
Watch when investigators move from individuals to organizations
The earliest warning in this case wasn’t a prosecution or an undercover operation.
It was the decision to expand the investigation from suspected individual violations into examining organizations that help people register to vote.
That’s the point to recognize next time.
When investigators begin compiling lists of civic organizations and searching government databases for damaging information about them, the question should be what evidence justified selecting those organizations in the first place.
And when the search finds nothing, what happens next?
If investigators close the inquiry, the government has followed the evidence to its conclusion.
If they keep expanding their search for something to use against an organization, despite finding no credible wrongdoing, a legitimate investigation may be turning into an attack on an independent institution.
The place to stop that Pattern is before the government turns the absence of evidence into a reason to keep looking.
Sources
1. Democracy Forward, October 7, 2026. Original 166-page ICE Homeland Security Investigations records, obtained through the Freedom of Information Act.
2. CNN, October 7, 2026. Gabe Cohen, Jeremy Herb and Tierney Sneed. Reports on ICE’s analysis of voter records, nonprofit investigations, proposed undercover activity and investigative findings.
3. Democracy Docket, October 7, 2026. Jacob Knutson. Details of nonprofit reviews in Pennsylvania, New Jersey and Ohio, including organizations flagged for additional examination.
4. Democracy Forward, October 7, 2026. Announcement and summary of its FOIA document production.
5. United States v. Adams, July 23, 2026. U.S. District Court for the Eastern District of Kentucky. Memorandum opinion dismissing the Justice Department’s voter-records lawsuit.
6. United States v. Adams. Case history, court filings and notice of the Justice Department’s July 24 appeal.
https://www.democracydocket.com/cases/kentucky-doj-voter-data-access-challenge/
7. U.S. House Committee on Homeland Security. Official committee description confirming oversight of ICE.
https://homeland.house.gov/border-security-facilitation-and-operations/
8. U.S. House Committee on Homeland Security. February 10, 2026 oversight hearing involving ICE, CBP and USCIS leadership.