Immigration and Customs Enforcement (ICE) has ramped up the I-9 workplace inspections, with offices in San Diego and Los Angeles combining to issue more than 300 Notices of Inspections in the past few weeks. Inspections by ICE and HIS have increased threefold each year, with worksite investigations increasing from 1,691 to 6,848 annually. Although ICE has respected “enforcement-free zones” during past emergency situations, it does not appear to be concerned with the negative effects that the COVID-19 outbreak has created.