Original Date Announced

President Trump federalized a minimum of 2,000 National Guard personnel under 10 U.S.C. § 12406 "to temporarily protect [Immigration and Customs Enforcement] and other United States Government personnel who are performing Federal functions, including the enforcement of Federal law, and to protect Federal property." The federalization is not geographically limited, prospectively federalizing National Guard units "at locations where protests against these functions are occurring or are likely to occur based on current threat assessments and planned operations." The federalization is to last for 60 days or a duration determined by the Secretary of Defense.

The presidential memorandum also authorizes the Secretary of Defense to deploy "any other members of the regular Armed Forces as necessary to augment and support the protection of Federal functions and property in any number determined appropriate in his discretion."

Trump 2.0 [ID #1806]

Subsequent Trump and Court Action

2025.06.09 Reported: 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."

Subsequent Trump and Court Action

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 it lacked the authority to mobilize those Guard units. Newsom v. Trump, No. 3:25-cv-04870 (N.D. Cal.).

**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

2025.06.10 Reported: 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."

Subsequent Trump and Court Action

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)."

Subsequent Trump and Court Action

2025.06.12 TRO - Newsom 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. Newsom v. Trump, No. 3:25-cv-04870 (N.D. Cal.).

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

Subsequent Trump and Court Action

2025.06.18 Complaint - Los Angeles Press Club v. Noem

Two nonprofit organizations supporting journalists, along with six individuals, filed suit to challenge DHS's use of force against protestors, journalists, and legal observers during demonstrations against immigration raids in Los Angeles. The plaintiffs state that DHS officers "unnecessarily and indiscriminately targeted, assaulted, tear-gassed, pepper-sprayed, and shot protesters exercising their right to assemble . . . , reporters covering these events, and legal observers seeking to document the government’s conduct." The complaint alleges that DHS’s actions violate the First Amendment and constitute excessive force. Los Angeles Press Club v. Noem, No. 2:25-cv-05563 (C.D. Cal.).

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

Subsequent Trump and Court Action

2025.06.19 Order Granting Stay of TRO Pending Appeal - Newsom v. Trump

A Ninth Circuit panel granted the federal government’s request for an emergency stay of the district court’s June 12, 2025 TRO, allowing federal control of the California National Guard to remain in effect pending appeal. The court held that the President's decision to federalize the National Guard under 10 U.S.C. § 12406, while justiciable, merits significant deference and that it is likely that the President acted within his statutory authority under § 12406(3). Newsom v. Trump, No. 3:25-cv-04870 (9th Cir.).

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

Subsequent Trump and Court Action

2025.07.07 Reported: Federal Agents March Through L.A. Park, Spurring Local Outrage - New York Times

Dozens of armed federal agents, accompanied by 80 California National Guard troops, entered a prominent park in one of Los Angeles' most immigrant-heavy neighborhoods. The agents arrived in armored vehicles and were equipped with fatigues, masks and helmets as they marched through MacArthur Park. While DHS described the scene as an immigration-enforcement operation, local officials contend that the show of force was a part of the federal government's ongoing efforts to intimidate LA's immigrants and residents.

Subsequent Trump and Court Action

2025.07.16 Reported: Trump’s National Guard Troops Are Questioning Their Mission in L.A. - New York Times

National Guard servicemembers are reporting low morale and decreasing retention rates as a result of President Trump's deployment of the National Guard for immigration enforcement operations in Los Angeles and elsewhere. At least two servicemembers who objected to the mission have been reassigned elsewhere. Out of the 72 soldiers whose enlistments will expire during the employment, 2 have left the Guard and 55 more have indicated that they will not extend their services; this would constitute a 21 percent retention rate, significantly lower than the typical 60 percent retention rate across the National Guard.

Subsequent Trump and Court Action

2025.09.02 Opinion Granting Injunctive Relief - Newsom v. Trump

Judge Charles R. Breyer granted California's request for an injunction, ruling that Defendants violated the Posse Comitatus Act by using "armed soldiers (whose identity was often obscured by protective armor) and military vehicles to set up protective perimeters and traffic blockades, engage in crowd control, and otherwise demonstrate a military presence in and around Los Angeles." The Court rejected the government's asserted "constitutional exception" to the Posse Comitatus Act for the protection of federal property and personnel: "This assertion is not grounded in the history of the Act, Supreme Court jurisprudence on executive authority, or common sense." The Court’s injunctive relief only applies to Defendants’ National Guard deployment in California, and is stayed until September 12, 2025. Newsom v. Trump, No. 3:25-cv-04870 (N.D. Cal.).

Subsequent Trump and Court Action

2025.09.10 Preliminary Injunction - Los Angeles Press Club v. Noem

U.S. District Judge Hernán Vera issued a preliminary injunction enjoining DHS’s use of excessive force against journalists, legal observers, and protestors in the Central District of California. The court held that plaintiffs were likely to succeed on their First Amendment claims, finding that the “federal agents’ indiscriminate use of force . . . will undoubtedly chill the media’s efforts to cover these public events and protestors seeking to express peacefully their views on national policies.” Los Angeles Press Club v. Noem, No. 2:25-cv-05563 (C.D. Cal.).

Separately, Judge Vera also granted a preliminary injunction against the LAPD for its use of force against journalists during the protests. Los Angeles Press Club v. City of Los Angeles, No. 2:25-cv-05423 (C.D. Cal.).

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

Subsequent Trump and Court Action

2025.09.28 Complaint - Oregon v. Trump

The State of Oregon and the City of Portland filed a lawsuit against the Trump administration to challenge the Oregon National Guard's federalization and deployment to perform federal law-enforcement functions in Portland. President Trump authorized the DHS Secretary and DOD Secretary to employ “Troops” using “Full Force” in Portland on September 27, 2025, announced via a post on social media. On September 28, DOD Secretary Pete Hegseth issued a memorandum calling into federal service 200 Oregon National Guard troops.

The complaint states that the federal government "infringed on Oregon’s sovereign power to manage its own law enforcement activity and National Guard resource," noting "[w]hile the Guard has over 6,500 total members, only a fraction of those are presently available for assignment over the next six months." It alleges that the administration's actions violate federal statutes as well as the Constitution's Tenth Amendment, Take Care Clause, Militia Clause, and separation of powers principles. The lawsuit asks for a permanent stay of the federal deployment order. State of Oregon v. Trump, No. 3:25-cv-01756 (D. Or.).

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

Subsequent Trump and Court Action

2025.10.04 TRO - State of Oregon v. Trump

U.S. District Judge Karin J. Immergut granted the State of Oregon's Motion for Temporary Restraining Order, temporarily enjoining the Trump administration from implementing Defense Secretary Hegseth’s memorandum federalizing the Oregon National Guard and ordering their deployment to Portland. The court found that the State is likely to succeed on the merits of their claim that the President's federalization of the Oregon National Guard exceeded his statutory authority under 10 U.S.C. § 12406.

The Court found the President did not have a colorable basis to invoke § 12406(3) to federalize the Guard because the "situation on the ground belied an inability of federal law enforcement officers to execute federal law." Further, the Court held that the President did not have the authority under § 12406(2) because the relevant protests did not rise to a "rebellion" and did not pose a "danger of a rebellion." The President's actions also violated Oregon's sovereign interest under the Tenth Amendment because he federalized the Guard absent constitutional authority.

The TRO expires on October 18, 2025. State of Oregon v. Trump, No. 3:25-cv-01756 (D. Or.). For the Ninth Circuit's subsequent administrative stay allowing federalization but not deployment, see this link.

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

Subsequent Trump and Court Action

2025.10.05 Second TRO - State of Oregon v. Trump

The States of Oregon and California moved for a second Temporary Restraining Order to stay the active deployment of federalized members of the California National Guard in Oregon. Oregon alternatively asked the court to modify its October 4, 2025 TRO to prohibit relocation or deployment of the National Guard under Defendants' command within Oregon. This motion responds to 101 federalized members of the California National Guard arriving in Oregon on October 5, 2025, after the court issued its first TRO. Judge Immergut granted a second TRO, temporarily enjoining Defendants from deploying federalized members of the National Guard in Oregon.

This TRO expires on October 19, 2025. State of Oregon v. Trump, No. 3:25-cv-01756 (D. Or.).

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

Subsequent Trump and Court Action

2025.10.08 Order Staying First TRO - State of Oregon v. Trump

The Ninth Circuit issued an order administratively staying the district court's first TRO in State of Oregon v. Trump. The stay allows the administration to federalize the Oregon National Guard but does not affect the second TRO, which temporarily prevents deployment of any federalized National Guard. The court found that administratively staying the first TRO will "best preserve the status quo" while the case proceeds. State of Oregon v. Trump, No. 3:25-cv-01756 (D. Or.).

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

Subsequent Trump and Court Action

2025.10.17 Complaint - Harris v. Lee

A group of local and state officials in Tennessee filed suit against Governor Bill Lee and other state leaders to challenge the Governor's activation and deployment of the Tennessee National Guard to Memphis for civilian law-enforcement purposes. The complaint alleges that President Trump signed a memorandum on September 15, 2025, creating the “Memphis Safe Task Force” and directing the Secretary of Defense to request that Governor Lee “make available National Guard units of Tennessee” to support “public safety and law enforcement operations in Memphis.” Governor Lee issued a press release committing Tennessee National Guard personnel to the Memphis Safe Task Force on the same day.

The complaint alleges that deploying Guard troops in this manner violates the Tennessee Constitution and state law provisions constraining the governor’s use of the military for law enforcement. Plaintiffs seek a declaration that the deployment is unlawful and an injunction against such deployment. Harris v. Lee, No. 25-1461 (Chancery Court for The State of Tennessee, Davidson County).

**See litigation note above**

Subsequent Trump and Court Action

2025.10.20 Order Granting Stay Pending Appeal - Oregon v. Trump

The Ninth Circuit issued an order, with dissent, granting an emergency stay pending appeal of the district court's October 4, 2025, temporary restraining order enjoining President Trump's order to federalize 200 members of the Oregon National Guard in Portland. The majority held that Defendants are likely to succeed on their claims that President Trump lawfully exercised his statutory authority pursuant to § 12406(3), and that federalization of the Guard did not violate the Tenth Amendment. Oregon v. Trump, No. 25-6268 (9th Cir.).

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