Illegal Alien Murder Cases: Victims, Laws, and Sanctuary Policy

Several illegal immigrant murder cases have reshaped American immigration politics over the past decade: Kate Steinle in San Francisco, Sarah Root in Iowa, Laken Riley in Georgia, Rachel Morin in Maryland, Jocelyn Nungaray in Houston, and a growing list of others. Each involved a victim killed by someone who was in the country without legal status, and in most of them the suspect had already come to the attention of immigration or local authorities before the killing. Those cases have driven federal legislation, the reopening of a dedicated victims’ office at the Department of Homeland Security, and a sweeping change in enforcement priorities, even as the leading peer-reviewed research continues to find that undocumented immigrants are arrested for homicide at lower rates than U.S.-born citizens.

Kate Steinle and the Case That Started a Movement

Kate Steinle was fatally shot on a San Francisco pier on July 1, 2015. Jose Ines Garcia Zarate, a Mexican national who had been deported multiple times, had recently been released from a San Francisco jail despite an ICE detainer request. His defense argued the shooting was accidental, saying a gun wrapped in cloth discharged when he picked it up.¹

In November 2017, a San Francisco jury acquitted Garcia Zarate of all homicide charges and convicted him of being a felon in possession of a firearm. That conviction was later overturned on procedural grounds. In March 2022, he pleaded guilty to two federal counts of illegal firearm possession and was sentenced to time served — seven years — plus three years of probation, with deportation to follow.²³

The case became the catalyst for the national sanctuary city debate and inspired Kate’s Law, a proposal to increase penalties for illegal reentry into the United States that has been reintroduced in multiple congressional sessions.⁴

Laken Riley

Laken Riley, a 22-year-old nursing student, was killed on February 22, 2024, while jogging on the University of Georgia campus in Athens. Jose Antonio Ibarra, a Venezuelan national who entered the United States illegally in 2022, was charged with her murder.⁵

Ibarra waived his right to a jury trial. On November 20, 2024, Clarke County Superior Court Judge H. Patrick Haggard found him guilty on all ten counts of the indictment, including malice murder, felony murder, kidnapping with bodily injury, aggravated assault with intent to rape, aggravated battery, obstruction of a 911 call, tampering with evidence, and a peeping-tom offense. The judge cited “overwhelming” evidence, including DNA found under the victim’s fingernails and digital evidence placing Ibarra at the scene. He was sentenced to life in prison without the possibility of parole.⁵ In March 2026, Judge Haggard denied Ibarra’s motion for a new trial, calling the state’s evidence “overwhelming and powerful.”⁶

Ibarra’s brother Diego was swept into the investigation after police approached him because of his resemblance to the suspect. He presented a counterfeit green card, was arrested, and later pleaded guilty to two counts of possessing a fraudulent document. He was sentenced to 48 months in federal prison, to be followed by deportation. Authorities indicated he was likely affiliated with the Venezuelan gang Tren de Aragua.⁷

Rachel Morin

Rachel Morin, a 37-year-old mother of five, was kidnapped, raped, and murdered in August 2023 while jogging on the Ma and Pa Heritage Trail in Bel Air, Maryland. Her body was found in a drainage culvert on August 6, 2023. Victor Antonio Martinez-Hernandez, a 24-year-old Salvadoran national, was arrested in Oklahoma in June 2024 after a nationwide manhunt, when DNA from the crime scene was linked to an earlier assault and home invasion in Los Angeles.⁸

According to the Department of Homeland Security, Martinez-Hernandez had entered the United States illegally in February 2023 after being expelled on three prior occasions. He was the subject of an active Red Notice from El Salvador at the time, wanted for aggravated femicide in the killing of another woman.⁹

A Harford County jury convicted him in April 2025 of first-degree murder, first-degree rape, third-degree sexual offense, and kidnapping. On August 11, 2025, he received the maximum penalty allowed: life without parole plus a consecutive life sentence plus 40 years. Psychological evaluators described him as marked by “coldness, dismissiveness, and a callous attitude” and a complete absence of remorse.¹⁰ Rachel’s mother, Patty Morin, later testified before the House of Representatives about what she described as failures of federal border policy.⁸

Jocelyn Nungaray

Twelve-year-old Jocelyn Nungaray was killed on June 16, 2024, in Houston. Her body was found the next morning beneath a bridge. Two Venezuelan nationals, Johan Jose Martinez Rangel, 22, and Franklin Jose Peña Ramos, 26, were charged with capital murder and sexual assault. Both had entered the country illegally and been apprehended by Border Patrol near El Paso in the months before the killing, then released with notices to appear in immigration court.¹¹

The Harris County District Attorney’s Office is seeking the death penalty against both defendants. As of mid-2026, both remain in the Harris County Jail on $10 million bonds each, with no trial date set.¹²

Other Recent Cases

The Modesto Triple Homicide

On May 28, 2026, authorities in Modesto, California, found the bodies of 54-year-old Maria Silvia Nuñez-Villalobos, her 23-year-old daughter Fabiola Gonzalez-Nuñez, and Fabiola’s two-week-old son Mateo. Joaquin Escoto, 28, a Mexican national from Jalisco who had reportedly been deported three times, was arrested at a neighboring residence and charged with three counts of murder along with child abuse causing death and child endangerment. A surviving four-year-old child, also fathered by Escoto, was found alive and placed in protective custody.¹³

Escoto pleaded not guilty. DHS said ICE had previously issued a detainer following an earlier DUI arrest, but the request was not honored and he was released.¹⁴ Prosecutors have filed a special-circumstance allegation of multiple murders and are weighing whether to seek the death penalty.¹⁵

Sarah Root

Sarah Root, an Iowa resident, was killed in January 2016 by an undocumented immigrant who was driving drunk. Her case became the basis for Sarah’s Law, later incorporated as an amendment to the Laken Riley Act.¹⁶

The Wisconsin Toddler Case

Akira Salinas-Ruiz was convicted in 2007 of first-degree reckless homicide for the death of 18-month-old Santiago Teniente Jr. in Manitowoc County, Wisconsin. The toddler died on March 1, 2006, from what doctors described as abusive head trauma consistent with shaken baby syndrome. Salinas-Ruiz was sentenced to 20 years in state prison.¹⁷ An immigration judge ordered his removal in 2008 while he was incarcerated, and ICE arrested him on February 17, 2026, upon his release and deported him.¹⁸

Laws Passed and Proposed in Victims’ Names

Several pieces of federal legislation have been introduced or enacted in direct response to these killings:

The Laken Riley Act, signed into law by President Trump in January 2025, requires federal detention of noncitizens arrested or charged with offenses including theft, shoplifting, assault on a police officer, or crimes causing injury or death. Sarah’s Law, named for Sarah Root, was incorporated as an amendment. By late December 2025, 17,500 people had been arrested and detained under the act.¹⁶¹⁹
The Justice for Jocelyn Act, introduced in July 2024 by Senator Ted Cruz and Representative Troy Nehls, would require ICE detention beds to be filled and would subject released immigrants to GPS monitoring.¹¹
The Justice for Angel Families Act, introduced in May 2025 by Senators Bill Cassidy and Roger Marshall, would provide federal funds for medical expenses, lost wages, and funeral costs for families of victims killed by illegal immigrants, and would codify the VOICE Office at DHS into permanent law.²⁰
The Justice for Victims of Illegal Alien Murders Act, introduced in May 2025 by Representative Morgan Luttrell, was referred to the House Judiciary Committee.²¹
Kate’s Law, named for Kate Steinle, would increase penalties for illegal reentry into the United States. Versions have been introduced in multiple congressional sessions.⁴

The Detainer Problem and Sanctuary Policies

A recurring element in these cases is a suspect with prior contact with law enforcement or immigration authorities who was released rather than turned over to ICE. That pattern has driven a sharp fight over sanctuary policies, meaning state or local laws that limit cooperation with federal immigration enforcement.

In June 2026, the House Judiciary Committee opened investigations into sanctuary policies in San Francisco and San Diego, demanding records on ICE detainer requests. The Committee pointed to the November 2025 death of 11-year-old Aiden Antonio Torres De Paz, struck and killed in a hit-and-run by a man who had been deported four times. The San Diego County Sheriff’s Office had rejected an ICE detainer for the suspect, citing compliance with California’s Values Act.²²²³

The Committee reported that California jurisdictions had refused ICE detainer requests resulting in the release of 4,561 individuals with criminal records in a single year. San Francisco Sheriff Paul Miyamoto acknowledged his office had honored only one of “thousands of requests for detention” from ICE. On the other side, the San Diego City Council passed a Due Process and Safety Ordinance in April 2026 requiring a judicial warrant before federal immigration agents can access non-public city property, and the county Board of Supervisors passed a separate measure prohibiting county law enforcement from assisting with deportations.²²

VOICE and the Angel Families

The Victims of Immigration Crime Engagement Office, originally created by President Trump in 2017 and shut down during the Biden administration, was reopened in April 2025. VOICE runs a hotline for victims and their families, helps them access a perpetrator’s criminal and immigration history, notifies them about custody-status changes, and refers them to social services. It also runs the Angel Families Project, which connects families of victims for roundtable discussions and public advocacy.²⁴

In its first year back, the hotline received 897 calls, with 588 victims seeking support. More than 62 percent of the crimes reported involved assault, rape and sexual assault, or homicide and manslaughter, and nearly two-thirds of callers were seeking information about an offender’s custody status.²⁴

What the Data Actually Shows

The headline cases exist alongside a research record that researchers describe as pointing the other way at the aggregate level. The most rigorous data comes from Texas, the only state whose criminal records systematically include immigration status verified through DHS fingerprint databases. A peer-reviewed study published in the Proceedings of the National Academy of Sciences in 2020 analyzed Texas Department of Public Safety arrest data from 2012 through 2018 and found that undocumented immigrants had consistently lower felony arrest rates than both native-born U.S. citizens and legal immigrants across every major crime category. For homicide specifically, the study found native-born citizens were roughly twice as likely to be arrested as undocumented immigrants.²⁵

A 2024 National Institute of Justice-funded study by Michael T. Light, using the same Texas dataset, reported that undocumented immigrants averaged 1.9 homicide arrests per 100,000 people between 2012 and 2018, compared to 4.8 per 100,000 for U.S.-born citizens. The study found “no evidence that the prevalence of undocumented immigrant crime has grown for any category” over that period.²⁶ Broader national analyses of FBI Uniform Crime Reporting data and census figures from 1980 to 2022 reported that as the immigrant share of the population more than doubled, from 6.2 percent to 13.9 percent, the total crime rate dropped by more than 60 percent, with no statistically significant state-level correlation between immigrant population share and crime rate.²⁷

A Government Accountability Office report on the State Criminal Alien Assistance Program cautioned that most jurisdictions do not systematically record immigration status in criminal records, and that SCAAP data was designed for reimbursement rather than crime-rate calculation. Among the state prison systems the GAO examined — Arizona, California, Florida, New York, and Texas — the most common primary offenses for incarcerated SCAAP aliens were drug, homicide, and sex offenses, reflecting the fact that individuals with serious convictions serve longer sentences and are overrepresented in any snapshot of prison populations. The GAO said its findings “are not generalizable to all criminal aliens or all state prison systems.”²⁸

For the families of Laken Riley, Rachel Morin, Jocelyn Nungaray, Kate Steinle, Sarah Root, and the others, the aggregate figures offer no consolation, and their advocacy has already reshaped federal law.

1
ABC7 San Francisco. Kate Steinle Murder Suspect Found Not Guilty
2
KCRA. Time Served in 2015 San Francisco Pier Killing of Kate Steinle
3
U.S. Department of Justice. Jose Inez Garcia-Zarate Pleads Guilty to Federal Firearm Charges in Death of Kate Steinle
4
Roll Call. House Passes Bill to Increase Penalties for Illegal Entry Into U.S.
5
ABC News. Laken Riley Suspect Found Guilty of Murder
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CBS News Atlanta. Judge Denies New Trial for Jose Ibarra in Laken Riley Murder Conviction
7
U.S. Department of Justice. Three Venezuelans Sentenced to Prison for Possessing Fake Green Cards
8
WBAL-TV. Rachel Morin Killer Victor Martinez-Hernandez Sentenced
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Court TV. Rachel Morin’s Killer Given Two Life Sentences Without Parole
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Harford County State’s Attorney’s Office. Maximum Penalty Imposed for Brutal 2023 Ma and Pa Trail Murder
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Houston Landing. As the Capital Murder Case of 12-Year-Old Jocelyn Nungaray Goes to Court, Here’s What to Know
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Houston Public Media. Jocelyn Nungaray’s Death Sparked Outcries About Immigration
13
New York Post. Case of Illegal Migrant Accused of Killing Family
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CBS News Sacramento. Man Accused of Murder of Modesto Family Appears in Court
15
Modesto Bee. Joaquin Escoto Triple Murder Case Court Proceedings
16
U.S. Senator Joni Ernst. Ernst’s Sarah’s Law Signed by President Trump
17
Twin Cities Pioneer Press. 20-Year Term in Manitowoc Toddler’s Death
18
U.S. Immigration and Customs Enforcement. ICE Arrests Violent Criminal Illegal Alien Who Murdered Toddler in Wisconsin
19
Migration Policy Institute. Trump 2 Immigration First Year
20
U.S. Senator Bill Cassidy. Cassidy, Marshall Introduce Bill to Support Families of Victims Killed by Illegal Immigrants
21
U.S. Congress. H.R.3294 – Justice for Victims of Illegal Alien Murders Act
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U.S. House Judiciary Committee. Congress Opens Investigations Into San Francisco, San Diego’s Sanctuary City Policies
23
NBC San Diego. Man Pleads Not Guilty in Deadly Hit-and-Run of 11-Year-Old Escondido Boy
24
U.S. Immigration and Customs Enforcement. Victims of Immigration Crime Engagement (VOICE)
25
Proceedings of the National Academy of Sciences. Comparing Crime Rates Between Undocumented Immigrants, Legal Immigrants, and Native-Born US Citizens in Texas
26
U.S. House Judiciary Committee. Unauthorized Immigration, Crime, and Recidivism: Evidence From Texas
27
Brennan Center for Justice. Debunking the Myth of a Migrant Crime Wave
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U.S. Government Accountability Office. GAO-18-433: Criminal Alien Statistics