her two kids (id. at 426-27). Under these circumstances, the Government failed to meet its burden to show probable cause that Pacheco was likely to escape before a warrant could be obtained. United States v. Khan, 324 F.Supp.2d 1177, 1187 (D. Colo. 2004), Because the ICE officers lacked “reason to believe” Pacheco posed a risk of escape before they could obtain an administrative arrest warrant for his removal proceedings, his warrantless arrest violated 8 U.S.C. § 1357(a)(2). See, e.g., Arizona, 132 S.Ct. at 2506 (“[ICE officers] may arrest an alien for being in the United States in violation of any [immigration] law or regulation, ... but only where the alien ‘is likely to escape before a warrant can be obtained.” (emphasis added)- (quotation omitted)); Khan, 324 F.Supp.2d at 1187 (<HOLDING>). 3. Suppression Is Warranted Under the Fourth
holding felony escape in north carolina to be crime of violence under acca because escape presents risk of injury to others holding a failure to appear for sentencing constitutes an escape under the rule holding that khans arrest was in violation of 8 usc  1357a2 due to governments failure to show risk of escape holding attempt to rescue prisoner and assisting in escape to be crimes of violence because of inherent risk of force holding that necessity defense to escape did not require defendant to turn herself in and that escape is not a continuing offense