Trump, via close subordinates and agents of U.S. Immigration and Customs Enforcement (ICE), has kidnapped, detained, and removed, without any due process, hundreds of people who peacefully live in our country. These people have been stolen from the streets of their communities, moved from state to state to evade court oversight, held without access to attorneys and family, and, in some cases, removed from the country and imprisoned in dangerous conditions in foreign countries in defiance of court orders. In carrying out this breathtaking and illegal assault on immigrants—including refugees, students, and other lawful visa-holders—Trump has undermined the First Amendment, abused his power to seek retribution against people who hold views with which he does not agree, unconstitutionally defied court orders and usurped judicial authority, unconstitutionally impeded local and state authority, and targeted individuals on the basis of their religious, ethnic, or racial identities. And he is now threatening to expand this scheme of kidnapping disfavored people and sending them to foreign prisons to include U.S. citizens. Examples of individuals who are being persecuted and wrongly imprisoned include:

• Kilmar Armando Abrego Garcia: A father of three who has lived in the United States since fleeing gang violence as a teenager, Mr. Abrego Garcia holds a “withholding of removal” status to prevent his removal to El Salvador because of the high likelihood that he would face persecution upon his return. But on March 12, 2025, he was stopped by ICE agents, arrested in front of his five-year-old son, and, with no warrant and no lawful basis, taken into custody, moved across multiple state lines, and flown to El Salvador where he was immediately imprisoned in a maximum security prison known for its rampant human rights abuses and disappearances of prisoners. His imprisonment is being funded by the Trump administration, which is paying millions of taxpayer dollars to El Salvador to imprison immigrants removed from the United States. Like others being held in El Salvador following their removal from the United States by the Trump administration, Mr. Abrego Garcia has not been charged with any crime in either country. Despite multiple court orders, including a court order of the United States Supreme Court, the Trump administration has refused to facilitate his return. Thus far, only one U.S. Senator has been able to meet with Mr. Abrego Garcia since his unlawful arrest and removal from the United States. He has otherwise been denied all visitors, a human rights violation to which all prisoners at the prison have been subject.

• Rümeysa Öztürk: A Fulbright scholar with a master’s degree from Columbia University and current PhD candidate at Tufts University, Ms. Ozturk was illegally and baselessly stripped of her student visa, kidnapped by masked ICE agents, taken across multiple state lines in order to evade court oversight, and ultimately taken to a private prison in Louisiana, where she is still being held in detention more than a thousand miles from her community and her attorneys. Her sole offense was co-authoring an op-ed in a student newspaper, asking the university to abide by undergraduate student Senate resolutions that sought to hold Israel accountable for international law violations against Palestine.

• Mahmoud Khalil: A recent recipient of a master’s degree from Columbia University, a lawful permanent resident of the United States, and a soon-to-be father, Mr. Khalil has been imprisoned since March 8, 2025. ICE officials arrested him in his apartment building in New York without a warrant and removed him to Louisiana, where he is being held in a private prison over a thousand miles from his attorneys, family, and community. The U.S. State Department revoked his visa and is seeking to deport him. He has not been charged with any criminal offense. He was arrested and remains in detention because he helped lead pro-Palestine protests at Columbia University when he was a student there. Mr. Khalil is Palestinian with Algerian citizenship.

• Venezuelan migrants: Senior Trump officials were involved in smuggling Venezuelan migrants out of the United States via planes that took off in secret and in order to evade court oversight. The migrants were taken to El Salvador in shackles and immediately taken to a maximum security prison, where they remain in detention without access to attorneys and other basic human rights and are likely being subjected to forced labor. The United States has entered into an agreement to pay El Salvador to imprison migrants. Although Trump and senior Trump officials claim that these individuals are members of a Venezuelan gang, they have not presented any evidence to support these claims.

These three examples have, to date, received the most public and judicial attention, but they represent a tiny fraction of the hundreds, if not thousands of people disfavored by Trump, whom Trump and his subordinates have illegally removed from the country and placed in concentration camps and other forms of cruel and unusual punishment on foreign soil and whose ongoing detention is being paid for by U.S. taxpayers. And given Trump’s plan to expand this scheme to include U.S. citizens, they will represent an even tinier fraction of all those who risk being disappeared to foreign countries, tortured in foreign prisons, and placed out of reach of U.S. rights, courts, and due process.

Trump has implemented an unlawful, unconstitutional, and costly scheme to smuggle people out of the United States and keep them in foreign prisons and concentration camps without due process, trial, access to the courts, or access to any of the rights to which they are entitled. Once smuggled out of the country, senior Trump officials are disavowing responsibility for the prisoners, their wellbeing, or their rights, even as the U.S. government pays foreign governments to keep the migrants confined. Trump and his senior officials are using the foreign imprisonment that they orchestrated and funded as an excuse to defy court orders and return the migrants to U.S. soil. And Trump is preparing to expand this scheme to imprison U.S. citizens in foreign concentration camps. Trump, senior officials within his administration, and agents of ICE and other federal agencies have:

• Paid El Salvador $6 million to accept and imprison more than 230 mostly Venezuelan men who sought refuge in the United States in a notorious and overcrowded maximum security prison known as Centro de Confinamiento del Terrorismo (CECOT), where prisoners are denied basic human rights, including education, recreation, and visitors, and subjected to forced labor. Senior Trump officials were involved in smuggling Venezuelan migrants out of the United States via planes that took off in secret and in order to evade court oversight. Although Trump and senior Trump officials claim that these individuals are members of a Venezuelan gang, they have not presented any evidence to support these claims, nor does membership in a gang warrant removal to a foreign country or being subject to human rights violations.

• Forcibly and unlawfully removed Kilmar Armando Abrego Garcia to CECOT, in violation of a court order prohibiting Mr. Abrego Garcia’s removal to El Salvador, a country he fled as a child to escape persecution by El Salvadorian gangs. Since he was unlawfully smuggled out of the country, Mr. Abrego Garcia has been imprisoned in El Salvador, subject to human rights abuses, and denied access to attorneys and visitors. Senior Trump officials have refused to facilitate his return, in defiance of multiple court orders, and he remains in unlawful detention under abusive, inhumane conditions.

• Arrested, shackled, and forcibly removed more than 100 migrants to Panama because their countries of origin would not accept them. The migrants were stripped of their passports, many had their phones taken away, barred from seeing lawyers, and locked as prisoners in a hotel in Panama. They were then removed to a camp in a remote jungle of Panama, where they were denied access to their attorneys or visitors.

• Arrested and deported hundreds of migrants to Panama and Costa Rica, where they are being held without access to attorneys, their families, or any of the rights to which they are entitled as migrants seeking refuge in the United States.

• Announced plans to expand this scheme to include the removal of U.S. citizens to foreign prisons; specifically, by telling Salvadoran President Bukele that “[t]he homegrowns are next, the homegrowns. You’ve got to build about five more places.”

These schemes violate the U.S. Constitution and international human rights laws. The clear violations, and the risk that these violations could be expanded to target not just American citizens but specifically those who engage in constitutionally protected speech to dissent against Trump, were laid out in a unanimous three-judge ruling of the U.S. Court of Appeals for the Fourth Circuit in Mr. Abrego Garcia’s case, written by the Honorable Judge Harvie Wilkinson:

“The government is asserting a right to stash away residents of this country in foreign prisons without the semblance of due process that is the foundation of our constitutional order. Further, it claims in essence that because it has rid itself of custody that there is nothing that can be done. This should be shocking not only to judges, but to the intuitive sense of liberty that Americans far removed from courthouses still hold dear.”

Judge Wilkinson further warned:

“If today the Executive claims the right to deport without due process and in disregard of court orders, what assurances will there be tomorrow that it will not deport American citizens and then disclaim responsibility to bring them home? And what assurance shall there be that the Executive will not train its broad discretionary powers upon its political enemies? The threat, even if not the actuality, would always be present, and the Executive’s obligation to ‘take Care that the Laws be faithfully executed’ would lose its meaning.”

Trump’s removal of anyone—whether migrant or U.S. citizens—to a foreign concentration camp for imprisonment in order to subject these individuals to cruel and unusual punishment, due process violations, civil rights abuses, and human rights violations without consequence or oversight is an unequivocal assault on the rule of law and on the foundation of our democracy.

Trump has unlawfully arrested, detained, and is now attempting to deport and revoke the permanent residency status of Mahmoud Khalil because he peacefully exercised his rights under the First Amendment. He has furthermore threatened to carry out other unlawful arrests, detentions, and deportations of individuals who peacefully protest on behalf of Palestine, in defiance of the First Amendment and U.S. immigration law. These protesters have First Amendment rights, and the exercise of their rights of association, speech, and protest cannot be the basis for revoking their visas or permanent residency status, nor can their religious affiliation or country of origin.

Trump has usurped or attempted to usurp authority and powers granted to Congress by the Constitution in several significant ways. He has:

• Created a position of authority in and over federal agencies and installed Musk in that position, in violation of the Advice and Consent Clause of the U.S. Constitution. 

• Defied both Congress and the Judiciary by blocking the distribution of trillions of dollars in funds that have been appropriated by Congress under Congress’s exclusive constitutional authority, under the Taxing Clause and the Appropriations Clause of the U.S. Constitution, U.S. Const. art. 1, sec. 8, cl. 1 and art. 1, sec. 9, cl. 7.

Trump and his administration have refused to comply with court orders, including by refusing to release $2 billion in congressionally appropriated foreign aid payments after being ordered to do so twice by a U.S. District Court and by the U.S. Supreme Court. In defying this and other court orders, Trump has violated the U.S. Constitution and trampled on the powers afforded to the Judiciary Branch by the Founders in order to check abuses of power from the other branches of government. Trump and his administration have:

• Refused to release $2 billion in foreign aid, in defiance of multiple court orders.

• Refused to adhere to court orders that prohibits the Office of Management and Budget from implementing a freeze on all federal assistance.

• Unlawfully deported 261 Venezuelan immigrants to El Salvador for immediate imprisonment, in open defiance of a court order, and demanded the judge’s impeachment solely because Trump disagrees with the judge’s ruling.

• Deported a doctor and medical school professor with a valid work visa, in defiance of a court order or in disregard of court proceedings and knowledge of an imminent court order.

• Refused to adhere to a court order requiring U.S. Office of Personnel Management (OPM) Charles Ezell to testify in person on March 13, 2025, in a lawsuit challenging Ezell and OPM’s termination of thousands of employees.

Trump, via his close subordinates and agents, has abused the power of his office to seek retribution against perceived adversaries, including hundreds of nonpartisan career public servants within the Department of Justice and the Federal Bureau of Investigation who were merely carrying out their duties. FBI agents, DOJ attorneys, and all federal employees are expected to carry out their duties impartially, regardless of the wealth, power, or status of the individuals they prosecute, and they are now being persecuted for diligently doing their jobs.

• Unlawfully firing federal law enforcement and attorneys involved in special counsel Jack Smith’s investigation into Trump and the prosecution of Trump for violations of federal law; 

• Unlawfully firing federal law enforcement and attorneys involved in investigating and prosecuting Trump’s January 6 co-insurrectionists;

• Unlawfully investigating attorneys who were involved in the prosecution of Eric Adams;

• Persecuting retired General Mark A. Milley, who served as Chairman of the Joint Chiefs of Staff from 2019 to 2023 under both Trump and Biden, including by revoking his security clearance and security detail and ordering the Department of Defense to investigate him; 

• Stripping former public officials of security details despite these individuals facing credible foreign or domestic threats, including former secretary of state Mike Pompeo, former director of the National Institute of Allergy and Infectious Diseases Anthony Fauci, and other former officials who served in Trump’s own administration.

The persecution of these officials undermines the independence of the DOJ, the FBI, and other federal agencies, and the agencies’ ability to protect the American people from abuse, corruption, and crimes committed by people with power or influence.

Trump has abused his power to fire officials from key government positions and curtailed federal agencies’ ability to carry out their missions. His act will prevent independent government oversight of his own businesses and those of his benefactors, including billionaire Elon Musk, who with Trump’s encouragement and complicity gave $260 million in contributions to his own super PACs to support Trump’s 2024 campaign; promoted a massive disinformation campaign on X, a/k/a Twitter, which Musk owns; and engaged in an unlawful million-dollar lottery scheme to bribe voters to vote for Trump. Trump has:

• Ordered the unlawful termination of more than 17 duly appointed inspectors general of U.S. agencies, who served as nonpartisan public servants charged with preventing government waste, fraud, and abuse. Many were terminated after or while their agencies carried out investigations into Musk-owned companies. 

• Ordered the Department of Justice from investigating any violations of the Foreign Corrupt Practices Act, which prohibits U.S. corporations and individuals from bribing foreign government officials to obtain a business advantage. The stop order will allow businesses controlled by Trump, his family, and his allies to bribe foreign governments without oversight or consequence. 

• Appointed Musk—whose businesses have 100 contracts worth $15.4 billion across 17 federal agencies—to lead the Department of Government Efficiency (DOGE). Though Congress did not create DOGE or confirm Musk to any official office, DOGE has authorized or advised the termination of thousands of federal employees, frozen trillions of dollars in federal grant funds, limited agency activities, and unlawfully accessed private data held by federal agencies, including private taxpayer information. 

• Fired the National Labor Relation Board’s (NLRB) General Counsel and one Democratic NLRB Board Member, leaving the NLRB without quorum or authority to adjudicate cases. The NLRB was pursuing 24 investigations into Musk-owned companies and had filed a case against Musk’s SpaceX.

• Ceased operations of the Office of Federal Contract Compliance Program (OFCCP), which enforces equal employment laws for federal contractors and was investigating Musk-owned Tesla. 

• Fired two Democratic, Senate-confirmed commissioners of the bipartisan Equal Employment Opportunity Commission (EEOC), leaving it without quorum. It is charged with protecting employees from unlawful and discriminatory hiring practices; it sued Tesla for racial harassment and retaliation in 2023—a lawsuit the DOJ has now moved to dismiss. 

• Suspended all investigative work and other critical operations by the Consumer Financial Protection Bureau (CFPB), fired employees, and gave DOGE access to its sensitive data. It is tasked with protecting consumers from unfair and deceptive practices from banks and other financial service providers. Had it not been shuttered, it would have regulated Musk-controlled X’s planned mobile payments services, and continued to supervise the auto lending industry, including Tesla. 

• Laid off or bought out between 4 and 10% of the National Highway Traffic Safety Administration employees, including 3 of the 7 experts in an office that oversees the safety of autonomous vehicles; it has 3 active investigations into Tesla. 

Trump has imposed harmful tariffs on countries across the world, which usurps powers explicitly reserved to Congress pursuant to U.S. Const. art. I, § 8, abuses his limited power under the International Emergency Economic Powers Act (IEEPA), and violates multiple trade agreements. The tariffs have undermined the United States economy, led to retaliatory tariffs from trade partners, had devastating effects on stock and bond markets, and crippled the economic security of Americans and American businesses. The United States faces significant risk of recession even as other Trump policies undermine consumer and labor protections.

Moreover, Trump is using and is positioned to use illegal tariffs to corruptly benefit his own and his allies’ financial interests and entrench his political power. First, Trump already has exempted certain industries and electronics from his broad tariffs and remains positioned to abuse his power to grant exemptions or set punitive tariffs that benefit his and his allies’ financial interests. Second, Trump’s abrupt imposition of tariffs and equally abrupt pause on these tariffs may have been part of market manipulation or insider trader schemes that benefited government officials and external allies who improperly used their advanced knowledge of Trump’s orders for improper financial gain.

The Domestic and Foreign Emoluments Clauses of the Constitution prohibits the president from profiting from the United States, individual states, or foreign governments (U.S. Constitution, art. I, sec. 9, cl. 8; and art. II, sec. 1, cl. 7). The Founders understood these clauses to provide a critical safeguard against corruption. Trump has refused to relinquish his ownership stake in his companies, including real estate holdings and golf resorts; the Trump Media & Technology Group, which owns Truth Social; and World Liberty Financial. He already has or is assured to receive substantial payment and benefit from foreign governments, from the United States, and from the several states; and he has enabled Musk to do the same.

Trump has attempted to unconstitutionally commandeer local and state authority to carry out his mass deportation plans by threatening state and local officials with criminal prosecution if they decline to be co-opted by federal immigration authorities. In a blatant disregard to the power reserved to the states under the Tenth Amendment, Trump via his then-Acting Deputy Attorney General issued a memorandum asserting the authority to require state and local actors to comply with the Executive Branch’s anti-immigration enforcement commands, and the authority to prosecute state and local officials who do not do the federal government’s bidding. The threat of even a baseless, unlawful prosecution may chill state and local officials and undermine their ability to determine how best to service their communities.

The President’s power to declare an emergency affords Trump access to powers and authority not normally afforded to the President. He has abused this power by falsely declaring national emergencies in order to bypass the rule of law, further his own agenda, and confer privileges on favored business sectors. He has:

• Declared a national emergency to justify deployment of troops at the U.S. border. In this declaration, Trump targets undocumented immigrants, dangerously and falsely calling efforts by vulnerable people to seek sanctuary in our country an “invasion” tantamount to an “attack” on “America’s sovereignty.” Immigration is neither, and there is no basis for either a national emergency or troop deployment within our borders. 

• Improperly declared a national energy emergency to protect and benefit fossil fuel companies and to block the renewable energy sector.

Trump has abused the pardon power and undermined due process of law. 

• Trump pardoned more than 1,500 January 6 co-insurrectionists, commuted the sentences of 14 additional co-insurrectionists, and ordered the Department of Justice to drop cases against all remaining January 6 defendants. He has absolved even those 400 insurrectionists who were charged with committing violent crimes against law enforcement. After inciting the insurrection, Trump has now blocked our country’s efforts to hold his fellow insurrectionists accountable and in so doing further protects himself from investigation and repercussions of his own role in the insurrection. 

• Trump pardoned 23 anti-abortion protesters, signaling that he will undermine any and all lawful efforts to hold anti-choice protesters accountable for violent assaults on doctors, medical professionals, patients, and medical clinics that provide reproductive health care; and undermine states’ rights to protect reproductive health care, the medical professionals who provide it, and the individuals who need it.

Trump has entered into a corrupt quid pro quo agreement with New York City Mayor Eric Adams by arranging for the DOJ to dismiss a criminal case against Adams in return for Adams using city resources to enforce Trump’s federal immigration agenda. Through Assistant Attorney General Emil Bove, he also retaliated against the U.S. attorney who resigned rather than file the improper dismissal by subjecting her to investigation and placing her former colleagues on leave pending investigation.

Birthright citizenship has been enshrined in our Constitution for more than 150 years, unequivocally and without exception conferring citizenship on “All persons born or naturalized in the United States.” In lawless defiance of the Constitution, Trump issued an executive order purporting to strip U.S.-born citizens of their citizenship because of their parents’ immigration status. The order has been stayed, but it does not absolve Trump of his abuse of power or Congress of its responsibility to hold Trump accountable for his dangerous and unlawful attack on U.S. citizens’ basic right to their own nationality.

The United States is facing unprecedented threats of foreign and domestic interference in U.S. elections, from entities that have the resources, tools, and capacity to hack our election systems and the emails of high-level officials, and to spread disinformation and propaganda via social media platforms. National intelligence agencies have concluded that Russia carried out a multifaceted assault on the 2016 election to benefit Trump, and that Russia, Iran, and China continue to attempt to interfere in US elections via hacking and widespread propaganda and misinformation campaigns. And pro-Trump operatives and election officials associated with efforts to overturn the 2020 election have unlawfully breached voting systems and obtained copies of voting machine software, which they have widely shared and which can be exploited to undermine our election systems. Despite these known risks, Trump has directly or through his close allies:

• Ordered the apolitical Cybersecurity and Infrastructure Security Agency (CISA) to halt all election security work and fired 130 CISA cybersecurity professionals; and 

• Disbanded the FBI taskforce assigned to investigate unlawful foreign influence in U.S. elections;

• Ordered the DOJ to investigate the state criminal conviction of Tina Peters, a Trump ally who gave a man unlawful access to voting equipment in May 2021, enabling the equipment’s passwords and copies of its hard drive to be posted online.

Trump has repeatedly declared his intention to unlawfully and forcibly displace Palestinians from Gaza and for the United States to unlawfully occupy Palestine and financially profit from its development. The forcible deportation of a civilian population from an occupied territory is a war crime under the Fourth Geneva Convention, a treaty to which the United States has been a party for more than 75 years, and qualifies as a felony offense under the U.S. War Crimes statute.

Trump must be investigated for unlawful, unconstitutional, or corrupt practices that occurred during his 2024 re-election campaign, which include:

• Violating campaign finance laws by (1) offering tax and regulatory favors to oil and gas executives if they provide $1 billion in contributions; (2) concealing legal services payments by his campaign and related super PACs; (3) unlawfully coordinating with super PACs that supported his candidacy, including those financed by billionaires he later appointed to key administrative positions; and (4) facilitating and accepting unlawful campaign contributions from Musk, particularly via Musk’s million-dollar “lottery” scheme that paid out prizes only to individuals who would publicly support Trump

• Using racist, xenophobic rhetoric that endangered the safety of marginalized communities

• Threatening physical violence against political opponents, a U.S. military commander, journalists, and protesters

• Spreading dangerous disinformation about U.S. hurricane disaster response that undermine the safety of natural disaster survivors and emergency response service providers.