Subsequent Trump and Court Action(s)

• January 27, 2025

  2025.01.27 Philadelphia Yearly Meeting of the Religious Society of Friends v. DHS Complaint (Case No. 8:25-cv-00243)

  A group of Quaker congregations filed suit in Maryland challenging DHS's rescission of its prior protected areas guidance. The Complaint argues that the threat of immigration enforcement in houses of worship "deters congregants from attending services, especially members of immigrant communities," and brings claims under the First Amendment, the Religious Freedom Restoration Act, and the Administrative Procedure Act. Philadelphia Yearly Meeting of the Religious Society of Friends v. DHS, 25-cv-00243 (D. Md.)

  **Litigation entries are limited to initial complaints and major substantive rulings. For pleadings and additional information, use name and docket number to search Civil Rights Clearinghouse and CourtListener or visit Just Security Litigation Tracker**

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• January 31, 2025

  2025.01.31 Protected Areas and Courthouse Arrests - ICE Memorandum

  ICE Acting Director Caleb Vitello issued a memorandum, Common Sense Enforcement Actions in or Near Protected Areas, stating that the January 20, 2025, DHS guidance in this entry recognizes that ICE law-enforcement personnel have discretion to consider various factors, including the degree to which law enforcement actions occur in protected areas. Protected areas include pre-schools through post-secondary schools; hospitals; churches, synagogues, mosques, or other institutions of worship; and a site during the occurrence of a public demonstration, such as a march, rally, or parade.

  The ICE memo says DHS is not setting bright-line rules on immigration-enforcement locations. Instead, it instructs Assistant Field Office Directors (AFODs) and Assistant Special Agents in Charge (ASACs) to make case-by-case determinations regarding whether, where, and when to conduct an immigration-enforcement action in or near protected areas. Before authorizing an action at a site where a public demonstration is underway, AFODs and ASACs must consult with the Office of Principal Legal Advisor for guidance on constitutional considerations.

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• February 5, 2025

  2025.2.12 Complaint, Denver Public Schools v. Noem, 1:25-cv-00474 (D. Colo.)

  Denver Public Schools (DPS) filed a lawsuit challenging DHS's rescission of the protected area guidance. The complaint argues that rescission has undermined the district's ability to create a safe educational environment, has caused a significant drop in student attendance, and forced school administrators and staff to "divert their time and resources away from their general educational duties." DPS alleges violations of the Administrative Procedure Act and the Freedom of Information Act, and seeks declaratory and injunctive relief. Denver Public Schools v. Noem, 1:25-cv-00474 (D. Colo.).

  **See litigation disclaimer in litigation entries above**

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• February 7, 2025

  2025.02.07 - USBP Chief Michael W. Banks on X

  United States Border Patrol Chief Michael W. Banks posts a video on X stating, “The U.S. Border Patrol has a long history of defending our country and our borders. Let me be very clear: United States Border Patrol agents do not target schools, school buses or churches.”

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• February 11, 2025

  2025.2.11 Complaint, Mennonite Church USA et al. v. DHS et al., 1:25-cv-00403 (D.D.C.)

  A diverse group of 27 Jewish and Christian denominational bodies filed a lawsuit in the D.C. District Court, challenging DHS's rescission of the protected areas guidance. The plaintiffs argue that the threat of immigration enforcement in their houses of worship profoundly burdens their religious exercise, and undermines "welcoming the stranger, or immigrant, [...] a central precept of [the plaintiffs'] faith practices." The complaint brings claims under the First Amendment, the Religious Freedom Restoration Act, and the Administrative Procedure Act. Mennonite Church USA v. DHS, 1:25-cv-00403 (D.D.C.).

  **See litigation disclaimer in litigation entries above**

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