Drawing on an original, interview-based case study of Immigration and Customs Enforcement (ICE) and a synthesis of six decades of social science literature, this Article offers a theory of physical violence in the administrative state that challenges foundational assumptions about administrative law. Approximately one-fifth of federal employees work for administrative agencies that police, fight wars, enforce immigration law, or incarcerate people—in other words, agencies that use force to execute the laws. These agencies are saturated with administrative law that obligates frontline administrators to confer due process, give notice, behave nonarbitrarily, and comply with law. Yet this law often fails to constrain administrators, with unauthorized violence as the result.

Conventional administrative law fails in these agencies because it has developed out of a model of the administrative state to which they do not conform. Most administrative law is designed around the organizational form and norms of bureaucracy. The characteristic role of bureaucracy is rational information processing using standardized rules and procedures. But the lower levels of these agencies belong to the domain of violence. They empower administrators to use physical violence in response to exigent circumstances––a different role, carried out within a different organizational form that has different norms and decision-making techniques. Ordinarily designed to safeguard core rule-of-law values, when bureaucratic administrative law is applied to agencies in the domain of violence, it often masks, and at worst accelerates, unauthorized violence.

For administrative law to potentially address unauthorized violence, it would have to override individuals’ responses and alter agency culture, requiring it to take different forms than bureaucratic administrative law usually does. Recognizing the domain of violence has practical and conceptual payoffs. It can help us understand how and whether law can check violence in the administrative state. And it opens up a universe of questions about the exceptional legal norms applied to agencies in this domain.