Here's the Chicago version -- a 100 plus page complaint at law, filed in the Dirksen Building tonight -- and a bit of it:
. . .Unable to force Illinois and Chicago through legal challenges to alter their policies, the federal government attempted to coerce the same result by unlawfully withholding federal funds. Defendant Noem issued a directive to cease federal funding to “sanctuary” jurisdictions.
The federal government then withheld millions of dollars in funds wholly unrelated to immigration -- including homeland security and disaster relief funds -- and promised to continue withholding funds unless and until Illinois diverted resources from the investigation and suppression of violent crime to federal immigration enforcement. Federal courts have barred the administration from implementing these illegal actions. See, e.g., Illinois v. FEMA, No. CV 25- 206 WES, 2025 WL 2716277 (D.R.I. Sept. 24, 2025); see also City & Cnty. of San Francisco v. Trump, 25-CV-01350-WHO, 2025 WL 2426858, at *2 (N.D. Cal. Aug. 22, 2025); Martin Luther King, Jr. Cnty. v. Turner, 798 F. Supp. 3d 1224, 1255 (W.D. Wash. 2025) (barring federal government from requiring Chicago to enforce federal immigration policies as a condition of receiving public safety, transportation and health grants).
Angered by his inability to force Illinois and Chicago to adopt his policies, President Trump threatened to unleash a military assault upon them. On September 6, 2025, the President shared on social media an image of himself dressed as a military officer from the film Apocalypse Now, rebranded as, “Chipocalypse Now." The post riffed on a line from the film in which a character celebrated using napalm on a Vietnamese village, writing “I love the smell of deportations in the morning. . .” Referring to the announcement by Trump and Secretary of Defense Peter Hegseth a day earlier that they would rebrand the Department of Defense as the “Department of War,” the post also threatened that “Chicago about to find out why it’s called the Department of WAR. . . .”
[Then, months later,] the United States Supreme Court denied the Trump administration’s application for an emergency stay concluding that “the Government has failed to identify a source of authority that would allow the military to execute the laws in Illinois.” Trump v. Illinois, No. 25A443, 2025 WL 3715211, slip op. at 2 (U.S. Dec. 23, 2025). . .” [See at right.]
Because of the purpose of border security (to prevent entry into the United States of smugglers, contraband, and undocumented immigrants) and the realities of border security (including rugged terrain where backup is often miles away and radio equipment frequently fails), Border Patrol agents operating at or near the border may engage in enforcement tactics that are not permissible for removal enforcement in the interior [like inside Chicago or Minneapolis], like warrantless searches of vehicles within a reasonable distance of the border and trespass on private property. CBP officers also may collect the biometric information of all noncitizens entering and leaving the United States, whereas such biometrics collection is only authorized in narrow, limited circumstances when effectuating removals. Compare 6 U.S.C. § 211(c)(10) (requiring Commissioner of Customs and Border Protection to “deploy technology to collect the data necessary for the Secretary to administer the biometric entry and exit data system”), and 8 U.S.C. § 1365b (addressing the creation of a biometric entry and exit data system), with 8 U.S.C. § 1357(f) (authorizing collection of biometric information from immigrants “14 years of age or older against whom a [removal] proceeding is commenced under section 1229a of this title”). . . .
Defendants have implemented an illegal policy of deploying Border Patrol to the interior of the United States [Where they are not authorized to operate], including the Chicagoland area. On October 30, 2025, Defendant Noem stated she was “thrilled with all the work that ICE and Border Patrol are doing to help clean up our streets. . . I would say that we actually are using our ICE officers and our CBP officers everywhere. . . .”
[Border Patrol was observed on video, on the Chicago Riverfront, and in Little Village,] patrolling in large numbers wearing military gear and brandishing military weapons in crowded areas of Chicago, including the Loop, Magnificent Mile, and Millenium Park, and interrogating people without belief the person was an alien or unlawfully in the country; arresting or detaining hundreds of people without a warrant or sufficient cause, and seemingly based solely on race or ethnicity; indiscriminately releasing tear gas in urban neighborhoods among civilian populations. . . .
[Since the early 1950s, under well settled federal law] U.S. citizens are not required to carry, much less produce upon request, documentation establishing their citizenship or otherwise prove their citizenship while going about their day. [But many are now doing so, to avoid these goon squads]. . . .
Commander-in-charge Bovino has acknowledged and affirmed the Roving Patrol Policy in stating to a reporter named Priscilla Alvarez: “I can question anyone anywhere in the United States as to their citizenship. Priscilla, what’s your citizenship? See I just did it now, and I can do that anywhere in the United States, and our border patrol agents are trained to do that.” [That is a false statement of the law. He is not so empowered.]. . . .
Updated: here's the Minnesota version of the memo of law, for those keeping score at home!
Onward, resolutely -- these people will not prevail. Our well-vetted system of ordered liberty will. Bank on that.
नमस्ते
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