Subsequent Trump and Court Action(s)

• June 9, 2025

  Reported: 2025.06.09 Protests intensify in Los Angeles after Trump deploys hundreds of National Guard troops - AP News

  President Trump authorized the deployment of 2,000 National Guard troops in Los Angeles after protestors responded to immigration raids in Los Angeles's fashion district by "attempt[ing] to block Border Patrol vehicles by hurling rocks and chunks of cement."

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• June 9, 2025

  2025.06.09 Complaint - Newsom v. Trump

  California Governor Gavin Newsom sued President Trump over his federalization of National Guard units in California. The complaint alleges that 10 U.S.C. § 12406 authorizes federalization only "(1) to repel invasion of the United States by a foreign nation, (2) suppress a rebellion or danger of rebellion against the authority of the Government of the United States; or (3) execute federal laws when the President is unable to do so with the regular forces," and that no such condition was met. The complaint further states that § 12406 "requires that orders pursuant to that section be 'issued through the governors of the States,'" and that President Trump and Secretary of Defense Hegseth failed to notify or obtain the Governor's permission. Finally, the complaint alleges that deployment violated the Posse Comitatus Act.

  The complaint also alleges violation of the Tenth Amendment, and that the Department of Defense's actions to implement the order were arbitrary and capricious because the it lacked the authority to mobilize those Guard units.

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• June 10, 2025

  Reported: 2025.06.10 Trump authorizes additional 2,000 National Guard members to Los Angeles, US officials say - AP News

  President Trump authorized deployment of 4,000 National Guard troops and 700 Marines to Los Angeles in response to protests "after federal immigration authorities arrested more than 40 people across the city." The deployment "escalat[ed] a military presence local officials and Gov. Gavin Newsom don’t want and the police chief says creates logistical challenges for safely handling protests."

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• June 11, 2025

  2025.06.11 US NORTHCOM - Update to DoD Federal Protection Mission

  U.S. Northern Command (NORTHCOM) states that "approximately 4,000 California Army National Guard soldiers were placed under federal command. . . . Additionally, approximately 700 Marines are augmenting the force." The press release states that the deployed soldiers "can and have accompanied ICE on missions, but they are not a part of the operations. Title 10 forces do not do law enforcement functions," adding that "approximately 2,800 service members are deployed to the greater Los Angeles area."

  NORTHCOM asserts that the deployed Marine battalion "underwent additional training specific to this mission . . . including] de-esclaation, crowd-control, and understanding the Standing Rules for the Use of Force (SRUF)."

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• June 12, 2025

  2025.06.12 TRO - Newsome v. Trump

  Judge Charles Breyer of the Northern District of California issued a temporary restraining order enjoining President Trump and Defense Secretary Hegseth from "deploying members of the California National Guard in Los Angeles" and "direct[ing] [them] to return control . . . to Governor Newsom." The Court stayed its order until noon on June 13, 2025.

  The Court held that it had authority to determine whether the statutory conditions for federalization have been met, and that no such conditions were present in Los Angeles. The court further held that the deployment was not issued through the Governor as required, and that Governor Newsom is likely to succeed on his Tenth Amendment claim. The Court did not rule on whether deployment violated the Posse Comitatus Act.

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