Original Date Announced

NIJC and the ACLU of Illinois filed a Motion to Enforce the 2022 Settlement Agreement in Castañon Nava, which outlined legal requirements for making warrantless arrests by ICE in Chicago. The motion alleges ICE has recently made 22 warrantless arrests that did not comply with the settlement agreement and asks the court to require ICE to comply with the settlement, provide records of all ICE arrests in the Chicago area since January 20, 2025, and order ICE agents assigned to Chicago to be retrained on the settlement requirements, among other forms of equitable relief. Castañon Nava v. DHS, No. 1:18-cv-03757 (N.D. Ill.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

Trump 2.0 [ID #2264]

Subsequent Trump and Court Action

2025.06.04 Reported: US immigration officers ordered to arrest more people even without warrants - The Guardian

The Guardian reports that senior ICE officials instructed immigration officers via email to “turn the creative knob up to 11” when it comes to enforcement. Officers were encouraged to come up with new ways of increasing arrests, including through potentially arresting “collaterals,” or undocumented immigrants whom officers encounter while serving arrest warrants for others.

Subsequent Trump and Court Action

2025.07.02 Amended Petition for Habeas Corpus and Complaint - Vasquez Perdomo v. Noem

Three detained plaintiffs—including two U.S. citizens—alongside the Coalition for Humane Immigrant Rights and Immigrant Defenders Law Center, filed a lawsuit in the District Court for the Central District of California challenging the Trump administration’s immigration raids across Southern California. The amended complaint alleges that federal immigration agents systematically conduct immigration stops and warrantless arrests without reasonable suspicion or individualized flight risk determinations, fail to identify themselves and provide reasons for arrests, and deny detainees access to legal counsel, in violation of the Fourth and Fifth Amendments, the Administrative Procedure Act, and various federal regulations. Plaintiffs seek habeas relief for the detained plaintiffs, class certification, a temporary restraining order, and injunctive relief to halt further enforcement actions in seven Southern California counties. Pedro Vasquez Perdomo v. Noem, No. 2:25-cv-05605 (C.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.07.11 Temporary Restraining Order - Vasquez Perdomo v. Noem

Judge Maame E. Frimpong of the Central District of California issued two temporary restraining orders enjoining Secretary of Homeland Security Noem from conducting indiscriminate immigration arrests “without reasonable suspicion” in the district and from denying detainees the right to consult with legal counsel. The Court held that the government “may not rely solely, alone or in combination” on race or ethnicity; the fact that someone speaks Spanish or English with an accent; presence at particular locations; or the type of work engaged in to “form reasonable suspicion for a detentive stop.” The Court further held that the plaintiffs are likely to prove that the federal government is conducting “roving patrols without reasonable suspicion and denying access to lawyers.” Pedro Vasquez Perdomo v. Noem, No. 2:25-cv-05605 (C.D. Cal.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.08.01 Denial of Stay Pending Appeal - Vasquez Perdomo v. Noem

The Ninth Circuit partially granted and partially denied the government's motion to stay the district court's temporary restraining order. The court stayed one provision barring the government from relying solely on four specific factors to form reasonable suspicion for a detentive stop "except as permitted by law." The court concluded that the language "except as permitted by law" rendered the paragraph impermissibly vague. Vasquez Perdomo v. Noem, No. 2:25-cv-05605 (9th Cir.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.08 Decision Granting Stay TRO - Vasquez Perdomo v. Noem

The U.S. Supreme Court granted the government's motion to stay the district court's temporary restraining order.

Justice Kavanaugh concurred, writing for himself that Plaintiffs likely do not have standing because "plaintiffs have no good basis to believe that law enforcement will unlawfully stop them in the future based on the prohibited factors—and certainly no good basis for believing that any stop of the plaintiffs is imminent."

Justice Kavanaugh added that the government is likely to succeed on Plaintiffs' Fourth Amendment claims, stating that while "apparent ethnicity alone cannot furnish reasonable suspicion; under this Court's case law regarding immigration stops . . . it can be a 'relevant factor' when considering other salient factors." He also asserted that the balance of harms and equities weighs in Defendants' favor because "the interests of illegal immigrants in evading questioning (and thus evading detection of their illegal presence) are not particularly substantial as a legal matter."

In dissent for herself and two colleagues, Justice Sotomayor called the stay "yet another grave misuse of our emergency docket," stating that "[t]he Government, and now the concurrence, has all but declared that all Latinos, U.S. citizens or not, who work low wage jobs are fair game to be seized at any time, taken away from work, and held until they provide proof of their legal status to the agents' satisfaction." Vasquez Perdomo v. Noem, No. 25A169 (U.S.)

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.25 Complaint - Escobar Molina v. DHS

CASA, a national nonprofit membership organization headquartered in Maryland, and four individuals brought a class action to challenge DHS and DOJ's practice of arresting individuals without a warrant and without probable cause as to immigration status and flight risk. The complaint alleges that the administration’s mass immigration stops and arrests have involved explicit racial profiling and targeted individuals whom federal agents "perceive to be Latino." Escobar Molina v. DHS, No. 1:25-cv-03417 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.10.07 Opinion and Order - Castañon Nava v. DHS

Judge Jeffrey Cummings of the U.S. District Court for the Northern District of Illinois issued an order granting in part plaintiffs' motion to enforce the 2022 Castañon Nava Settlement Agreement, which outlined legal requirements for warrantless arrests by ICE. The court granted plaintiffs' motion to modify the final order enforcing the settlement. The court found that ICE arrested 22 of the 26 class members without a warrant in violation of the settlement agreement and the law, and ordered ICE to provide relief to those individuals under the agreement. The court also found that modifying the agreement is warranted because of ICE's failure to comply, but declined to adopt plaintiffs' proposed modifications. The court instead extended the settlement until February 2, 2026, and will adjust ICE's reporting requirements to track its future compliance. Castañon Nava v. DHS, No. 1:18-cv-03757 (N.D. Ill.).

**Link to case here. See litigation disclaimer above**

Subsequent Trump and Court Action

2025.10.09 Complaint - Ramirez Ovando v. Noem

The ACLU of Colorado, the Meyer Law Office, and Olson Grimsley Kawanabe Hinchcliff & Murray, LLC filed a lawsuit on October 9, 2025, which seeks to enjoin ICE from conducting warrantless arrests in Colorado without probable cause that a person is a flight risk and present without proper legal documentation. The suit also seeks class certification for individuals who have been or will be subject to ICE’s warrantless arrests. The suit is brought on behalf of a lawful permanent resident (LPR), a DACA-recipient, an asylum seeker, and an undocumented business owner, all of whom have lived in the U.S. for over a decade. Ramirez Ovando v. Noem, No. 1:25-cv-03183 (D. Colo).

**Link to case here. See litigation disclaimer above**

Subsequent Trump and Court Action

2025.11.13 Order - Castañon Nava v. DHS

Judge Cummings granted plaintiffs’ motion for placement of potential class members on alternatives to detention, ordering the administration to release hundreds of detainees believed to have been arrested without warrants or probable cause in violation of the 2022 consent decree, many of whom were arrested during Operation Midway Blitz. The court ordered the government to release unconditionally the 13 class members whom the parties agree were unlawfully arrested; it also ordered the government to release 615 other class members on bond and ICE's Alternatives to Detention program (as long as they are not subject to mandatory detention). Judge Cummings also ordered ICE to stay deportation and voluntary departure proceedings for these individuals. The government must provide a list of names and threat levels of the remaining 3,000 to 3,300 individuals arrested since June 11, 2025. Castañon Nava v. DHS, No. 1:18-cv-03757 (N.D. Ill.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.11.20 Order - Castañon Nava v. DHS

The Seventh Circuit administratively stayed two orders issued by District Judge Jeffrey Cummings, one on October 7, 2025, and one on November 13, 2025, that required the release on bond of hundreds of immigrants detained during the Trump administration's enforcement surge in Illinois. The district court had found that ICE's use of informal administrative warrants during "Operation Midway Blitz" violated a 2022 settlement requiring judicial warrants for most arrests. The court gave no explanation for the stay, but scheduled oral arguments for December 2 on the Trump administration's motion for stay pending appeal. Castañon Nava v. DHS, No. 25-3050 (7th Cir.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.11.25 Order granting PI - Ramirez Ovando v. Noem

A federal judge issued a preliminary injunction barring ICE from conducting warrantless arrests in Colorado without "probable cause to believe that the individual is in the United States in violation of United States immigration laws and probable cause that the person being arrested is likely to escape before a warrant can be obtained." The court found that the plaintiffs sufficiently demonstrated that they were arrested without such probable cause, that the defendants likely have a pattern or practice of ignoring the individualized flight risk determinations required by federal law, and that this policy likely violates the APA. The court further granted plaintiffs’ motion for class certification. Ramirez Ovando v. Noem, No. 1:25-cv-03183 (D. Colo.).

**Link to case here. See litigation disclaimer above**

Subsequent Trump and Court Action

2025.12.02 Order - Escobar Molina v. DHS

U.S. District Judge Beryl Howell granted plaintiffs' motion to preliminarily enjoin defendants from making warrantless civil-immigration arrests in the District of Columbia without individualized probable-cause determinations for each arrestee's risk of escape. The court held plaintiffs are likely to establish jurisdiction over their claims, that the alleged policy and practice of warrantless arrests without probable cause is a final agency action, and that plaintiffs established a substantial likelihood that defendants' failure to apply the probable-cause standard violates Immigration and Nationality Act (INA) requirements and DHS's implementing regulations.

The court also granted plaintiffs' motion for class certification, certifying a class defined as: "All persons who, since August 11, 2025, have been or will be arrested in this District for alleged immigration violations without a warrant and without a pre-arrest, individualized assessment of probable cause that the person poses an escape risk." Plaintiffs' motion for final certification of a broader class and additional subclass was reserved for a later time. Escobar Molina v. DHS, No. 1:25-cv-03417 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.12.11 Order - Castañon Nava v. DHS

The Seventh Circuit granted in part and denied in part the government's motion to stay the October 7 and November 13 orders from the district court.

The court denied the request for a stay of the October 7, 2025, extension of the Castañon-Nava consent decree, holding that the government failed to show a likelihood of success as to its argument that the extension was an abuse of the district court's discretion.

As for the November 13, 2025, order, the court held that defendants are not likely to succeed in arguing that the noncitizens arrested in Chicago without an administrative warrant were subject to mandatory detention under § 1225(b)(2)(A). Nevertheless, the court held that the district court likely exceeded its authority when ordering the release of the 442 "potential" class members before making an individualized determination that they were arrested in violation of the consent decree. The court correspondingly granted the government's motion to stay the November 13 order. Castañon Nava v. DHS, No. 25-3050 (7th Cir.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.01.15 Complaint - Hussen v. Noem

Three individual Minnesotans filed a class action to challenge the administration's actions in Operation Metro Surge. The complaint alleges that federal immigration agents are stopping people without reasonable suspicion—and particularly targeting those perceived to be Somali or Latino—and making arrests without warrants or probable cause. The complaint also states that the arrests are "being carried out with an unprecedented level of violence." Plaintiffs allege that the administration's actions violate the Fourth and Fifth Amendments of the Constitution as well as federal statutory law, and seek declaratory and injunctive relief to halt these practices. Hussen v. Noem, No. 0:26-cv-00324 (D. Minn.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.04 Preliminary Injunction - M-J-M-A v. Wamsley

A federal judge in Oregon issued a preliminary injunction order barring the government from conducting warrantless civil immigration arrests without probable cause in the state. The court found that “[a]mple evidence in this case demonstrates a pattern and practice in Oregon that amounts to final agency action of executing warrantless arrests without individualized determination of flight risk.” The court found that the action is likely to be found unlawful and set aside under the APA.

The order also requires the government to report to the court every 30 days with detailed information on any warrantless civil immigration arrests that occurred that month, including evidence that an individualized assessment of escape risk was conducted. M-J-M-A v. Wamsley, No. 6:25-cv-02011 (D. Or.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

Subsequent Trump and Court Action

2026.02.17 Order - Castañon Nava v. DHS

Judge Cummings issued an order on plaintiffs’ motion to enforce the consent decree. Although it was set to expire on February 2, 2026, the court found that it remains in effect because plaintiffs filed motions to enforce beforehand. The court thus retained jurisdiction to consider motions to enforce for 30 days after defendants certified compliance.

Among other things, the court required defendants to produce arrest records of all noncitizens arrested since June 11, 2025, who were subject to a warrantless arrest or to arrest under circumstances where there is a genuine dispute about whether it was warrantless. The court also ordered the immediate release of certain noncitizens on their own recognizance and without bond or conditions pursuant to the consent decree. Castañon Nava v. DHS, No. 1:18-cv-03757 (N.D. Ill.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.19 Plaintiffs' Motion to Enforce Preliminary Injunction - Escobar Molina v. DHS

Escobar Molina Plaintiffs asked the court to enforce its preliminary injunction, alleging that "remarkably little has changed" about DHS's arrest practices: DHS continues to make arrests based on reasonable suspicion and without prior analysis of an individual's likelihood of escape. Plaintiffs also allege that DHS is violating reporting requirements by failing to ensure that its documentation of warrantless arrests includes "specific, particularized facts that supported the agent’s pre-arrest probable cause to believe that the person was likely to escape." Escobar Molina v. DHS, No. 1:25-cv-03417 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.27 Order - M-J-M-A v. Wamsley

District Judge Mustafa Kasubhai released a full opinion explaining its order from February 4, 2026, which enjoined ICE from making warrantless immigration arrests in the District of Oregon without a pre-arrest individualized determination of probable cause that the person being arrested is likely to escape before a warrant can be obtained. The opinion explains in detail that plaintiffs are likely to succeed on the merits of their claim that ICE’s arrest practice is contrary to law. It finds that plaintiffs have and will continue to suffer irreparable physical, financial, and emotional harm if the practice is not enjoined, and that the balance of equities and public interest favor preliminary relief. M-J-M-A v. Wamsley, No. 6:25-cv-02011 (D. Or.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.27 Order - Castañon Nava v. DHS

District Judge Jeffrey I. Cummings issued an order in Castañon Nava v. DHS on plaintiffs' order to enforce. The court granted a brief stay on the portion of a previous order requiring DHS/ICE to re-circulate the decree's "Broadcast Statement of Policy" to all ICE agents nationwide regarding warrantless arrests. The court then evaluated the warrantless arrests of five class members and found that ICE agents lacked probable cause in four of the cases. It also ordered the government to release 36 individuals on their own recognizance, without bond or conditions, pursuant to the Consent Decree. The court ordered the government to produce body camera footage for certain arrests and to produce files of at least 50 individuals per week, prioritizing those still in the United States. Castañon Nava v. DHS, No. 1:18-cv-03757 (N.D. Ill.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.03.09 Order on Motion for Preliminary Injunction - Hussen v. Noem

District Judge Eric Tostrud denied plaintiffs' motion for a preliminary injunction. The court held that plaintiffs lacked Article III standing to seek forward-looking injunctive relief because they could not show a "certainly impending" future injury. The court noted that no plaintiff had been stopped twice, and the significant reduction in Operation Metro Surge made future injury too speculative. The court further stated that it would conclude that plaintiffs are not entitled to a preliminary injunction even if they had standing. It found that plaintiffs are likely to prevail on the merits of their Fourth Amendment claims "that Defendants have a policy authorizing their officers to arrest individuals without probable cause to believe that the arrestee had committed a crime or was likely to escape before a warrant could be obtained," but that they failed to make out "a clear showing of immediate irreparable injury" for the same reasons that they lack standing.

The court also denied class certification, as "a class may not be certified if some of its members lack standing to bring the suit themselves," and "it is virtually certain that some individuals who were subject to unconstitutional immigration stops and arrests are not likely to be stopped or arrested unlawfully again."

Hussen v. Noem, No. 0:26-cv-00324 (D. Minn.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.03.18 Complaint - Peralta v. DHS

Four Ohio residents filed a class action lawsuit against the Trump administration to challenge its practice of conducting warrantless arrests for alleged immigration violations without probable cause or an individualized determination of likelihood of escape. The complaint alleges that the federal government's practice of conducting warrantless arrests is driven by directives to increase arrest numbers and violates federal law. Plaintiffs seek declaratory and injunctive relief, including an injunction requiring agents effectuating warrantless arrests to comply with the requirements set forth in DHS's Broadcast Statement of Policy, which was first issued in connection with proceedings in Castañon Nava v. DHS (see above). Peralta v. DHS, No. 2:26-cv-00337 (E.D. Ohio).

**Link to case here. See litigation note above**