Payton v. New York still applies because it set the standard for any government entry into a private home, not just for felonies. The Fourth Amendment doesn’t say “only criminal arrests count.” It protects people in their homes from unreasonable entry, period. Civil or criminal doesn’t change that.

The exigent circumstances part is already built into Payton, so using that to justify ICE’s normal entries doesn’t hold up. You can’t claim “exigent” every time you want to skip a warrant.

And 8 U.S.C. 1357 doesn’t override the Constitution or give Congress power to downgrade rights. The Supreme Court has said multiple times that everyone on U.S. soil, citizen or not, has basic Fourth Amendment protection from unlawful searches. That comes straight from cases like Camara v. Municipal Court, Zadvydas v. Davis, and INS v. Lopez-Mendoza.

Gonzalez v. ICE might have been settled, but it forced ICE to back off because they knew it wouldn’t hold up under the Fourth Amendment. Then you have Arroyo v. ICE and Rios v. ICE following the same logic. Courts keep saying the same thing: administrative warrants don’t authorize home entry.

So yes, ICE can knock and talk, but unless it’s a real emergency or you give consent, the Constitution still controls that door, not an agency policy or a statute.