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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

STATE OF ILLINOIS, a sovereign state; and

the CITY OF CHICAGO, an Illinois municipal
corporation,

Plaintiffs,

v.

DONALD J. TRUMP, in his official capacity Case No. 25 Cv 12174

as President of the United States;
DEPARTMENT OF HOMELAND Judge
SECURITY; KRISTI NOEM, in her official
capacity as Secretary of the Department of
Homeland Security; DEPARTMENT OF
DEFENSE; PETER B. HEGSETH, in his
official capacity as Secretary of the
Department of Defense; UNITED STATES
ARMY; DANIEL P. DRISCOLL, in his
official capacity as Secretary of the Army,

Defendants.

COMPLAINT FOR EMERGENCY, DECLARATORY, AND INJUNCTIVE RELIEF

Introduction

1. The American people, regardless of where they reside, should not live under the

threat of occupation by the United States military, particularly not simply because their city or state

leadership has fallen out of a president’s favor. To guard against this, foundational principles of

American law limit the president’s authority to involve the military in domestic affairs. Those

bedrock principles are in peril. Secretary Hegseth, on October 4th, invoked 10 U.S.C. § 12406 to

federalize and bring under Department of Defense control up to 300 members of the Illinois

National Guard, over the objection of the Governor of Illinois (“Federalization Order”), and, on

October 5th, another up to 400 National Guard from the State of Texas to deploy into Chicago
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(“Texas Mobilization Order”). These advances in President Trump’s long-declared “War” on

Chicago and Illinois are unlawful and dangerous. The Court should enjoin the Federalization

Order, Texas Mobilization Order, and any subsequent effort to achieve the same end with the

National Guard of the United States or other U.S. military, immediately and permanently.

2. At the Pentagon on September 30, 2025, Trump pitched his plan to use American

soldiers to punish his political enemies to hundreds of United States military leaders. He told them

that they must prioritize “defending the homeland” against the “invasion from within” in American

cities run by “radical-left Democrats,” specifically including Chicago. He stated his intention to

use our neighborhoods “as training grounds for our military.”1

3. This is just the most recent in months of threats by Trump, Secretary of the

Department of Defense Peter Hegseth, Secretary of the Department of Homeland Security Kristi

Noem and others in the Trump administration—threats that are entirely unrelated to circumstances

in Illinois or the needs of federal law enforcement.

4. In one example that received significant news coverage, on September 6, 2025,

Trump posted on social media an image of the Chicago skyline in flames, stating “Chicago about

to find out why it’s called the Department of WAR,” including a depiction of himself in the image

of the fictitious warmonger character Lt. Col. Kilgore from the 1979 film Apocalypse Now, titling

the post “Chipocalypse Now.”

5. To the extent that Defendants have offered any basis at all to deploy the military to

Illinois, it is based on a flimsy pretext: protests outside a two-story ICE processing facility in

Broadview, a suburb of Chicago with less than 8,000 residents. But far from promoting public

1
The transcript is available at https://rollcall.com/factbase/trump/transcript/donald-trump-speech-
department-of-defense-leaders-quantico-september-30-2025/.
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safety in the Chicago region, Defendants’ provocative and arbitrary actions have threatened to

undermine public safety by inciting a public outcry.

6. Among other things, Trump and Noem have sent a surge of SWAT-tactic trained

federal agents to Illinois to use unprecedented, brute force tactics for civil immigration

enforcement; federal agents have repeatedly shot chemical munitions at groups that included

media and legal observers outside the Broadview facility; and dozens of masked, armed federal

agents have paraded through downtown Chicago in a show of force and control. The community’s

horror at these tactics and their significant consequences have resulted in entirely foreseeable

protests. In response to those protests, local and state law enforcement agencies, including the

Broadview Police Department, the Cook County Sheriff’s Office, the Illinois State Police, and

others, have been deployed to Broadview to maintain the peace. And ICE continues to operate the

facility to process the hundreds of individuals it has detained in recent weeks. There is no legal or

factual justification for Defendants’ Federalization Order.

7. Defendants’ deployment of federalized troops to Illinois is patently unlawful.

Plaintiffs ask this court to halt the illegal, dangerous, and unconstitutional federalization of

members of the National Guard of the United States, including both the Illinois and Texas National

Guard. Because this federalization is patently pretextual and baseless, Defendants cannot satisfy

any of the three prerequisites for involuntarily federalizing any of the National Guard of the United

States under 10 U.S.C. § 12406. Not only have the defendants acted outside the authority of 10

U.S.C. § 12406, but their conduct also violates the Posse Comitatus Act, the Administrative

Procedure Act, and, of paramount concern, several provisions of the U.S. Constitution.

8. The Trump administration’s illegal actions already have subjected and are

subjecting Illinois to serious and irreparable harm. The deployment of federalized National Guard,

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including from another state, infringes on Illinois’s sovereignty and right to self-governance. It

will cause only more unrest, including harming social fabric and community relations and

increasing the mistrust of police. It also creates economic harm, depressing business activities and

tourism that not only hurt Illinoisians but also hurt Illinois’s tax revenue. Illinois asks this Court

to declare these actions unlawful and enjoin them, immediately as well as permanently.

9. For these and other reasons discussed below, Defendants’ actions should be

declared unlawful and preliminarily and permanently enjoined.

Jurisdiction and Venue

10. This Court has jurisdiction over this matter under 28 U.S.C. § 1331 because this

matter arises under the Constitution, laws, or treaties of the United States.

11. This Court may provide the requested relief because there is a controversy under

28 U.S.C. § 2201(a), and this Court may grant declaratory relief, injunctive relief, and other

appropriate relief under 28 U.S.C. §§ 1361, 2201-2202, 5 U.S.C. §§ 702, 704-706, and the Court’s

equitable powers.

12. Venue lies in this district under 28 U.S.C. § 1391(b)(2) because a substantial part

of the events or omissions giving rise to the claim occurred in the Northern District of Illinois.

Parties

13. Plaintiff State of Illinois is a sovereign state in the United States of America. Illinois

is represented by Kwame Raoul, the Attorney General of Illinois, who is the chief legal officer of

Illinois and authorized to sue on the State’s behalf. Under Illinois law, the Attorney General is

authorized to represent the State’s interests by the Illinois Constitution, article V, § 15. See 15 Ill.

Comp. Stat. 205/4.

14. Plaintiff City of Chicago is a municipal corporation and home rule unit organized

and existing under the constitution and laws of the State of Illinois.

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15. Defendant Donald J. Trump is the President of the United States of America. He is

the Commander-in-Chief of the United States’ armed forces, including state National Guard units

when under federal control. He is sued in his official capacity.

16. The United States Department of Homeland Security (DHS) is a cabinet agency in

the Executive Branch of the federal government. DHS’s primary functions are preventing the entry

of terrorists and their weapons into our country; securing borders, territorial waters, ports,

terminals, waterways, and air; carrying out the immigration enforcement functions vested by the

Immigration and Naturalization Act, as well as establishing national immigration enforcement

policies and priorities; and administering customs laws. 6 U.S.C. § 202. U.S. Immigration and

Customs Enforcement (ICE) and U.S. Customs and Border Protection (CBP) are each component

agencies within DHS.

17. Defendant Kristi Noem is the Secretary of DHS. As Secretary, Defendant Noem is

responsible for all actions taken by the agency. She is sued in her official capacity.

18. Defendant United States Department of Defense (DoD) is a cabinet agency in the

Executive Branch of the federal government. DoD is responsible for coordinating the activities of

the United States’ armed forces, including the National Guard when under federal control.2

19. Defendant Peter Hegseth is the Secretary of Defense. As Secretary, defendant

Hegseth is responsible for all actions taken by the agency. He is sued in his official capacity.

2
On September 5, 2025, President Trump signed Executive Order 14347, entitled “Restoring the
United States Department of War,” purporting to assign “Department of War” as the secondary
chosen name for the Department of Defense. However, this Complaint will refer to the agency by
its statutory name, the Department of Defense, as only Congress is vested with the authority to
change the name of cabinet-level executive agencies, and it made no change.
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20. Defendant United States Army (Army) is the primary land service branch of the

United States military. The Army is a component of DOD, which is a cabinet agency in the

Executive Branch of the federal government.

21. Defendant Daniel P. Driscoll is the Secretary of the Army. He is the leader of the

Army and is responsible for all actions taken by the Army. He is sued in his official capacity.

Legal Background

I. The National Guard

22. The modern National Guard originates from the longstanding tradition of organized

local militias. During the Constitutional Convention, the founders recognized the importance of

militias. But they disagreed about who should control them. Federalists advocated for centralized

control by the federal government; anti-Federalists advocated for state authority.

23. The debate was resolved by a compromise reflected in the Militia Clauses of the

United States Constitution. These clauses provide Congress with the authority “[t]o provide for

calling forth the Militia to execute the Laws of the Union, suppress Insurrections and repel

Invasions” and “[t]o provide for organizing, arming, and disciplining, the Militia, and for

governing such Part of them as may be employed in the Service of the United States.” U.S. Const.

art. I, § 8, cls. 15. But the clauses “reserve[e] to the States respectively, the Appointment of the

Officers, and the Authority of training the Militia according to the discipline prescribed by

Congress.” Id. art. I, § 8, cls. 16.

24. States generally maintained control over local militias throughout the remainder of

the eighteenth and nineteenth centuries. It was not until Congress enacted the Militia Act of 1903

that the federal government began to assert greater control over these militias, which the statute

officially named the “National Guard.” Pub. L. No. 57-33, § 3, 32 Stat. 775.

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25. Federal control over the National Guard increased during the twentieth century,

culminating in the “Total Force Policy” announced by the Department of Defense in the 1970s.

Under this policy, the National Guard was incorporated into the military reserve. Later, in the

1990s, the National Guard further transitioned from a reserve force to an operational unit that could

be quickly activated and readily utilized in any major conflict.

26. In recent years, the National Guard has been deployed in a wide variety of missions,

ranging from providing emergency assistance during natural disasters to serving abroad in military

campaigns in Iraq and Afghanistan.

27. Today, members of the National Guard may serve in one of three capacities: State

Active Duty status, Title 10 status, and Title 32 status.

28. First, members of the National Guard may serve in “State Active Duty” status. This

means they exercise state functions under the authority of their state’s governor, and their actions

generally are governed by state law. When natural disasters occur in Illinois, for example,

Governor Pritzker frequently authorizes the Illinois National Guard to engage in relief efforts.

29. Second, members of the National Guard may be “federalized” and serve in what is

known as “Title 10” status. Under 10 U.S.C. § 12406, for example: “Whenever (1) the United

States, or any of the Commonwealths or possessions, is invaded or is in danger of invasion by a

foreign nation; (2) there is a rebellion or danger of a rebellion against the authority of the

Government of the United States; or (3) the President is unable with the regular forces to execute

the laws of the United States; the President may call into Federal service members and units of the

National Guard of any State in such numbers as he considers necessary to repel the invasion,

suppress the rebellion, or execute those laws.”

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30. Critically, the statute requires that an order for Title 10 deployment “shall be issued

through the governor[.]” 10 U.S.C. § 12406. Therefore, Illinois National Guard members may

serve in “Title 10” status only with the approval of the Governor. Once these National Guard

members have been “federalized,” they are, for all purposes relevant here, legally equivalent to

members of the federal armed services. In that posture, National Guard members serve federal

missions under federal command and control.

31. Third, members of the National Guard may serve in a hybrid status under Title 32

of the United States Code. In particular, 32 U.S.C. § 502(f)(2)(A) provides that, “[u]nder

regulations to be prescribed by the Secretary of the Army or Secretary of the Air Force, as the case

may be, a member of the National Guard may,” under certain circumstances, “be ordered to

perform” enumerated duties, including “[s]upport of operations or missions undertaken by the

member’s unit at the request of the President or Secretary of Defense.” Although National Guard

members serving in Title 32 status serve federal missions, they remain under the command and

control of their home state’s governor. E.g., 32 U.S.C. § 328(a), (c); see 10 U.S.C. § 12401; United

States v. Hutchings, 127 F.3d 1255, 1258 (10th Cir. 1997).

32. One crucial distinction between National Guard members deployed in Title 32 and

those deployed in Title 10 status is that only members deployed in Title 10 status are “federalized”

and functionally equivalent to members of the federal armed services. As members of the federal

armed services, National Guard members deployed in Title 10 status are subject to the Posse

Comitatus Act, which generally forbids military service members from participating in civilian

law enforcement activities.

II. The Posse Comitatus Act

33. The United States has a deeply rooted “‘traditional and strong resistance of

Americans to any military intrusion into civilian affairs.’” United States v. Dreyer, 804 F.3d 1266,
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1272 (9th Cir. 2015) (quoting Laird v. Tatum, 408 U.S. 1, 15 (1972)). This tradition is reflected in

the Third Amendment to the United States Constitution, which prohibits quartering of soldiers and

in other provisions ensuring civilian control of the military. Id.; U.S. Const. amend. III. The Illinois

Constitution also explicitly provides that “The military shall be in strict subordination to the civil

power.” Ill. Const. Art. XII, § 2.

34. This tradition is also reflected in the Posse Comitatus Act (PCA), 18 U.S.C. § 1385,

which prohibits use of the military to enforce civilian laws.

35. Congress first codified this principle in 1878, enacting the precursor to the modern

PCA to bring to an end to the use of federal troops to enforce the law in the former rebel states of

the south once civil government had been re-established. United States v. Yunis, 681 F. Supp. 891,

892 (D.D.C. 1988), aff'd, 924 F.2d 1086 (D.C. Cir. 1991).

36. The current version of the PCA makes it a felony to use the military “as a posse

comitatus or otherwise to execute the laws,” unless such use is “expressly authorized by the

Constitution or Act of Congress.” 18 U.S.C. § 1385.

37. Reinforcing the PCA is the Congressional directive of 10 U.S.C. § 275,

commanding the Secretary of Defense to “prescribe such regulations as may be necessary” to

ensure that any military support of civilian law enforcement activity “does not include or permit

direct participation by a member of the Army, Navy, Air Force, or Marine Corps in a search,

seizure, arrest, or other similar activity” unless specifically authorized by law. Newsom v. Trump,

No. 25-CV-04870-CRB, 2025 WL 2501619, at *29 (N.D. Cal. Sept. 2, 2025) (enjoining National

Guard actions executing the law because they would violate the PCA, “including but not limited

to engaging in arrests, apprehensions, searches, seizures, security patrols, traffic control, crowd

control, riot control, evidence collection, interrogation, or acting as informants”).

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38. National Guard members who have been called into federal service under 10 U.S.C.

§ 12406 are subject to both the PCA and the regulations promulgated under 10 U.S.C § 275. See

10 U.S.C. 12405 (“Members of the National Guard called into Federal service are, from the time

when they are required to respond to the call, subject to the laws and regulations governing the

Army or the Air Force . . .”); Department of Defense Instruction 3025.21, Defense Support of

Civilian Law Enforcement Agencies (“DODI 3025.21”) (applicable to federalized National Guard

members) and Enclosure 3 (prohibiting military participation in e.g., arrests, apprehension, stop

and frisk, crowd control).

39. 10 U.S.C. § 12406 does not contain any express authorization from Congress for

the National Guard to engage in domestic law enforcement, including civil immigration

enforcement.

40. The National Guard troops, when federalized, are legally the same as U.S. military,

and operate under the Department of Defense rules. Department of Defense guidance provides

instructions regarding the civilian law enforcement tasks, including direct assistance, that are not

allowed to be carried out by the U.S. military (including National Guard members federalized

under Title 10). DODI 3025.21.

41. Those Department of Defense instructions cover a broad swath of law enforcement

tasks and make clear that the directive of October 4 cannot lawfully be carried out by federalized

national guard troops. In particular, the Federalization Order and preceding memoranda and

statements identify policing protesters and crowd control functions that are squarely within the

Department of Defense’s own definition of prohibited civilian law enforcement by a U.S. military

member. DODI 3025.21, encl. 3, ¶ 1.c.(1).

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42. Similarly, the Immigration and Nationality Act (INA), which prescribes who may

execute immigration warrants and conduct immigration searches, arrests, and interrogation, makes

no provision for any member of the military or the National Guard to participate in these activities.

See 8 U.S.C. §§ 1357(a), (g); 8 C.F.R. §§ 287.5(a), (c)–(e). Nor do members of the military or

National Guard receive the training required by the INA to qualify them to carry out these

activities. 8 C.F.R. §§ 287.5(c)(1)–(4), (c)(5)(ii), (d), (e)(1), (e)(3), (e)(4).

Factual Allegations

I. Defendants Have a Long History of Animus towards Chicago and Illinois

43. President Trump has long directed threatening and derogatory statements towards

the State of Illinois, the City of Chicago, and its leaders.

44. The supposed current emergency is belied by the fact that Trump’s Chicago troop

deployment threats began more than ten years ago. In a social media post from 2013 Trump writes

“we need our troops on the streets of Chicago, not in Syria.”

45. As President, Trump would go on to characterize Chicago in October 2019 as “the

worst sanctuary city in America” that “protects criminals at a level few could even imagine,” and

further claiming that “Afghanistan is a safe place by comparison.”

46. In the spring and summer of 2020, when the killing of George Floyd by

Minneapolis police sparked nationwide protests and civil disturbances, President Trump derided

“the radical-left wing mobs that you see all over in some of the cities,” specifically citing Chicago

and “so many different places that are run by Liberal Democrats.”

47. Three years ago, in 2022, Trump was between his presidential terms. In two

separate speeches that summer, Trump shared his plans for Chicago, stating in July 2022 that the

“next president needs to send the National Guard to the most dangerous neighborhoods in

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Chicago.” He reiterated that point at the August 2022 CPAC speech, saying that the problem was

“these cities that were run by Democrats going so bad so fast.”

48. While running for his current term as President, Trump continued to demonize cities

where Democrats had been elected as leaders. On August 20, 2024, he said that “cities…almost all

are run by democrats…you can’t walk across the street to get a loaf of bread. You get shot, you get

mugged, you get raped, you get whatever it may be . . . .”

49. Since retaking office on January 20, 2025, Trump issued several executive orders

intended to deter states and localities from implementing or keeping “sanctuary” policies or laws—

laws that preclude components of state or local governments from participating in federal civil

immigration enforcement in various ways.

50. Those “sanctuary”-targeting Executive Orders, each issued earlier in 2025, were:

Executive Order 14159, Protecting the American People Against Invasion; Executive Order 14218,

Ending Taxpayer Subsidization of Open Borders; and Executive Order 14287, Protecting

American Communities from Criminal Aliens. All focus on defunding state and local “sanctuary

jurisdictions,” including by claiming that “sanctuary” jurisdictions “use their authority to violate,

obstruct, and defy the enforcement of Federal immigration laws,” and by accusing them of

undertaking a “lawless insurrection.” Executive Order 14287 ¶ 4.

51. From the Trump administration’s comments before and after these Executive

Orders, it was clear that they were meant to target, among others, the State of Illinois and City of

Chicago, which have laws making clear their non-participation in federal civil immigration

enforcement.

52. In 2017, Illinois passed the TRUST Act, 5 ILCS 805/15, which sets a

“[p]prohibition on enforcing federal civil immigration laws.” It was signed into law by Bruce

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Rauner, then-Governor of Illinois, a Republican. Ill. Pub. Act 100-463 (eff. Aug. 28, 2017). In

2021, Illinois enacted amendments to the TRUST Act, known as the Way Forward Act, that

expanded the limits on participation by state and local law enforcement in federal civil immigration

enforcement. Ill. Pub. Act 102-234 (eff. Aug. 2, 2021).

53. The City of Chicago Welcoming City Ordinance also generally prohibits local

Chicago law enforcement and other government participation in federal civil immigration

enforcement activities. Chicago Mun. Code § 2-173.

54. In 2022, the Seventh Circuit held that the TRUST Act, as amended by the Way

Forward Act, was “a permissible exercise of the State's broad authority over its political

subdivisions within our system of dual sovereignty.” McHenry Cnty. v. Kwame Raoul, 44 F.4th

581, 585 (7th Cir. 2022).

55. Soon after the “sanctuary jurisdiction” EO of Trump’s second term, the Trump

administration filed suit against the State of Illinois, City of Chicago, Cook County, and others,

seeking to invalidate their immigration-related laws. The United States alleged that the laws

created national security and public safety threats posed by noncitizens and violated the U.S.

Constitution. United States v. Illinois, No. 25 CV 1285 (N.D. Ill.) (filed Feb. 6, 2025) As explained

below, a federal district court in Chicago dismissed that lawsuit in July 2025. United States v.

Illinois, No. 25 CV 1285, 2025 WL 2098688, at *27 (N.D. Ill. July 25, 2025).

56. In addition to issuing EOs ordering defunding of “sanctuary” jurisdictions, and

suing the Plaintiffs and others, Trump made public statements threatening them, including on April

10, 2025, falsely claiming they protect criminals and calling them “Death Traps”:

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57. On April 18, 2025, Stephen Miller, White House Deputy Chief of Staff for Policy

and the Homeland Security Advisor leveled the accusation that “Sanctuary cities shield criminal

illegal aliens from removal.” Although not a lawyer, he opined that “these cities are engaged in

systemic criminal violations and that they are engaged in a scheme to nullify and obstruct the duly

enacted laws of the United States of America.” Miller specifically cited Chicago, along with Los

Angeles and Boston, saying the cities were “waging war against the very idea of nationhood.”

58. In accordance with the president’s effort to defund sanctuary cities, the Trump

administration, acting through various federal agencies, has sought to assert a sweeping

entitlement to use state law enforcement officers for federal immigration enforcement. It has done

so by requiring Illinois and other states to agree to cooperate with federal immigration enforcement

activities as a condition for receiving billions of dollars in federal funding.

59. For example, beginning in March 2025, the U.S. Department of Homeland Security

and its sub-agencies, including Federal Emergency Management Agency (“FEMA”), sought to

upend the state-federal emergency management system, holding critical emergency preparedness

and response funding hostage unless Illinois and other states promised to devote their criminal

enforcement and other state agency resources to the federal government’s civil immigration

enforcement.

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60. Forced to choose between foregoing federal funds or facing compulsory diversion

of limited law enforcement resources to enforce federal immigration law beyond what Illinois law

allows, Illinois, with other states, brought suit to challenge those coercive conditions. State of

Illinois v. Federal Emergency Management Agency, 25-cv-00206 (D.R.I.) (filed May 13, 2025).

In September 2025, the court granted summary judgment to the states, holding among other things

that those conditions violated the Constitution and were tantamount to “economic dragooning.”

Illinois v. Fed. Emergency Mgmt. Agency, No. CV 25-206 WES, 2025 WL 2716277, at *14 (D.R.I.

Sept. 24, 2025).

61. Illinois and other states have similarly challenged coercive immigration-

enforcement conditions by the U.S. Department of Transportation, California v. U.S. Dept. of

Transportation, 25-cv-00208 (D.R.I.) (filed May 13, 2025) and the U.S. Department of Justice,

New Jersey v. U.S. Dept. of Justice, 25-cv-00404 (D.R.I.) (filed August 18, 2025).

62. The funding for Illinois jeopardized by these coercive actions by the Trump

administration totals over $2 billion. Those funds are critical to the state’s service to its residents

and used by Illinois to maintain state and local roads and bridges, protect against and respond to

natural disasters, and provide emergency shelter to crime victims and conduct sexual assault

forensic exams, among other things.

63. In the midst of these immigration-related federal defunding actions and responsive

lawsuits, DHS published, on May 29, 2025, a list of 500 purported “sanctuary jurisdictions” around

the country. It accused them of “shamefully obstructing” the Trump administration’s deportation

plans and “shielding dangerous criminal aliens.” Fox News Channel 32 Chicago accurately

characterized the list as an escalation of “efforts to penalize states and cities that limit cooperation

with federal immigration authorities.”

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64. However, days later, based on widespread news reporting as early as June 1st, that

first sanctuary jurisdiction list was gone. As reported, very soon after publishing the list, the Trump

administration faced objections from Republican stronghold jurisdictions that found themselves

on the list. The Department of Homeland Security quickly and quietly removed the list from the

website where it had been posted.

65. Then on July 25, 2025, the federal district judge presiding over the United States’

lawsuit regarding Illinois’s, Chicago’s and Cook County’s immigration-related laws and policies

dismissed the case. United States v. Illinois, No. 25 CV 1285, 2025 WL 2098688, *27 (N.D. Ill.

July 25, 2025). In concluding that there was no claim for the United States to pursue, the court

held that “the Sanctuary Policies reflect [Illinois’s, Chicago’s and Cook County’s] decision to not

participate in enforcing civil immigration law—a decision protected by the Tenth Amendment and

not preempted by the INA. Finding that these same Policy provisions constitute discrimination or

impermissible regulation would provide an end-run around the Tenth Amendment. It would allow

the federal government to commandeer States under the guise of intergovernmental immunity—

the exact type of direct regulation of states barred by the Tenth Amendment.” Id.

66. Less than two weeks later, the Trump administration posted a new version of its

sanctuary jurisdiction target list. That August 5, 2025, publication shortened the list from about

500 to just 35 jurisdictions. The new sanctuary “jurisdiction” list targeted twelve states (including

Illinois, California, and Oregon), the District of Columbia, eighteen cities (including Chicago),

and four counties (including Cook County).

67. Although DOJ stated its intention in pressuring “sanctuary jurisdictions” was to

“compel compliance with federal law,” in reality the administration’s efforts sought to

impermissibly force sovereign states like Illinois to disavow their own laws and subjugate

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themselves to the political whim of the Trump administration. The August 5 publication

specifically bragged about the success of a “threatening” letter that coerced Louisville, Kentucky

to revoke its “sanctuary policies.”

68. Days later, on August 8, 2025, Noem on behalf of DHS appeared at a press

conference in a suburb near Chicago and continued the pressure on Plaintiffs to change their laws.

69. Specifically, defendant Noem stated that she was in Illinois because “elected

leaders in this State of Illinois are ignoring the law” and being “obstructionists when it comes to

getting dangerous criminal off of their streets.” She specifically named Governor Pritzker and

Mayor Johnson as examples of who she was claiming “worked so hard to protect these dangerous

criminals,” saying “they’d rather be a sanctuary state and continue to put those individuals above

American citizens.”

70. On August 13, 2025, defendants’ coercive conduct regarding state law continued.

That day, Attorney General Bondi sent letters to 32 of the 35 jurisdictions on the August 5 list,

including Governor Pritzker for Illinois, and Mayor Johnson for Chicago. The letters contended

that “sanctuary jurisdiction policies have undermined this necessary cooperation and obstructed

federal immigration enforcement, giving aliens cover to perpetrate crimes in our communities and

evade the immigration consequences that federal law requires.”

71. Bondi’s August 13 letters further stated that, to ensure full cooperation in federal

immigration enforcement efforts, “the President has directed the Attorney General of the United

States, in coordination with the Secretary of Homeland Security, to identify sanctuary jurisdictions

and notify them of their unlawful sanctuary status and potential violations of federal law.” The

letters did not include any specifics regarding any particular law(s), nor did they reflect any

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recognition of prior court rulings holding the state laws valid. The letter demanded a response by

August 19, 2025.

72. This letter from Attorney General Bondi followed Trump’s deployment of troops to

Los Angeles in June and Washington D.C. in early August, both jurisdictions on the Trump

administration’s “sanctuary jurisdictions” list.

73. On August 19, Governor Pritzker’s office replied in a letter that reiterated the state’s

adherence to its own laws, including the TRUST Act, and reminded the U.S. Attorney General that

federal courts had rejected the Trump administration’s legal challenges to those laws.3

74. Three days later, on August 22, 2025, during an Oval Office appearance to

announce the 2026 FIFA World Cup draw, Trump stated that Chicago would be the next target for

a military deployment as part of a federal crime crackdown. Trump stated at that event: “Chicago’s

a mess. You have an incompetent mayor, grossly incompetent and we'll straighten that one out

probably next. That'll be our next one after this and it won't even be tough.”

75. On August 25, Trump referenced again plans for a federal military deployment in

Chicago, stating “We go in, we will solve Chicago within one week, maybe less. But within one

week, we will have no crime in Chicago, just like we have no crime in D.C.” He also made a

social media post criticizing Chicago and Mayor Johnson and stating the desire to bring the

national guard D.C. playbook to Chicago:

3
Letter from A. Spillane to P. Bondi (Aug. 19, 2025), available at
https://www.politico.com/f/?id=00000198-cc6b-da96-abff-de6f2c310000.
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76. On August 29, 2025, on behalf of the Trump administration, Stephen Miller stated

that “the highest degree of national security and public safety concern are in sanctuary cities,” such

that the President would be “prioritizing enforcement in these sanctuary jurisdictions as a matter

of public safety and national security.”

77. When asked specifically about the administration’s plans for Chicago, Miller said

that “this administration is committed to the eradication of organized street violence . . . as one of

our top public safety objectives” and referenced “homegrown” threats as well as “foreign criminal

cartels.” Miller then made the outrageous and outlandish accusation that, “the Democrat party as

an institution at every level—its judges, its lawyers, its community activists, and its politicians—

exist to serve these criminal thugs.”

78. That same day, August 30th, Trump posted on Truth Social unsupported crime

statistics about Chicago and threatened that Governor Pritzker with federal forces, stating: “Six

people were killed, and 24 people were shot, in Chicago last weekend, and JB Pritzker, the weak

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and pathetic Governor of Illinois, just said that he doesn’t need help in preventing CRIME. He is

CRAZY!!! He better straighten it out, FAST, or we’re coming! MAGA. President DJT[.]”

79. Less than an hour later, Trump posted on Truth Social that “nothing can stop what

is coming:”

80. On September 1st, Trump again claimed that Chicago and Illinois, along with Los

Angeles, New York and Baltimore, should “work with” the Trump administration like in D.C.,

where the National Guard were deployed over the Mayor’s objection, and then Plaintiffs could be

“A CRIME FREE ZONE.”

81. The next day, September 2nd, in the Oval Office, Trump made clear that he planned

to deploy National Guard troops to Chicago. Trump was asked, “Have you decided you’re

definitely going to send National Guard troops to Chicago?”

82. In response, Trump criticized Governor Pritzker on crime, saying that, in “three

weeks, he’s lost almost 20 people, killed,” and calling Chicago “a hellhole” worse than

“Afghanistan.” When pressed with the follow up question, “Have you made your mind up on

Chicago though?,” Trump answered, “We’re going in. I didn’t say when, we’re going in.”

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83. Trump’s social media posts on September 2nd continued his pronouncements,

including a Truth Social post that falsely stated that “CHICAGO IS THE MURDER CAPITAL OF

THE WORLD!”

84. Another post by Trump that same day also falsely called Chicago the “worst and

most dangerous city in the World, by far.” The post stated that Governor “Pritzker needs help

badly,” and claimed Trump would “solve the crime problem fast, just like I did in DC.”

85. The next day, September 3rd, Trump repeated his Oval Office promise that “We’re

going into Chicago!” in a fundraising email to his supporters:

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86. 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, “Philocaly’s 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 defendant Hegseth a day earlier that they would rebrand the Department of Defense

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as the “Department of War,” the post also threatened that “Chicago about to find out why it’s called

the Department of WAR.”

87. Two days later, on September 8, defendant DHS announced, “Operation Midway

Blitz,” and stated that ICE “will target the criminal illegal aliens who flocked to Chicago and

Illinois because they knew Governor Pritzker and his sanctuary policies would protect them and

allow them to roam free on American streets.”

88. The Trump administration then sent Chicagoland the same federal immigration

enforcement teams that had perpetrated workplace and other public raids in Los Angeles earlier in

2025. Those raids caused injuries and unconstitutional detentions, along with mass panic and

protest.

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89. The federal law enforcement teams sent to Chicago were led by same DHS

leadership from those Los Angeles, Customs and Border Protection Commander of Operations

Gregory Bovino. Many were from Custom and Border Protection’s Office of Field Operations’

Special Response Team (SRT), a specialized tactical unit analogous to SWAT.

90. Although DHS claimed the “blitz” was to nab “the worst of the worst criminal

illegal aliens in Chicago,” in reality the focus of the agents was warrantless civil immigration

arrests, not criminal arrests using criminal warrants. Although conducting arrests for civil

offenses, many agents were filmed using violent arrest tactics.

91. Nearly immediately, the brute force tactics had foreseeably harmful consequences.

For example, on the morning of September 12, 2025, in Franklin Park, Illinois, two of these DHS

agents shot and killed a longtime area resident and father, following an attempted warrantless

vehicle stop. The victim had just dropped off his toddler at daycare. DHS immediately put out a

statement putting the blame on the victim, which quickly was contradicted by witness videos.

92. Citizens already had expressed concern about ICE agent tactics, but the killing of

an unarmed man, along with a perceived cover-up and lack of accountability, increased community

ire.

93. The Chicago area federal immigration operation involves the use of the ICE

Processing Center on Beach Street in Broadview, Illinois, a suburb of Chicago. The modest, two-

story ICE facility is used to process immigrants who are subject to detention or removal under

U.S. immigration laws. The facility is not designed for holding detainees overnight, but reports

that detainees are being held there improperly drew community attention.

94. Small demonstrations began taking place outside the ICE facility months ago,

particularly a twice-weekly religious gathering and prayer vigil.

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95. Following the September “blitz” and particularly the killing of the local father,

protests outside Broadview became larger and more regular. Even so, the protests have been small,

most often with fewer than 100 people, including significant attendance by clergy, media, and local

elected officials. On September 12, in the morning, between 80 and 100 protestors assembled

outside the ICE facility in Broadview. Initially, the crowd was singing and chanting. Some of them

had small musical instruments. The crowd that morning included several older individuals and

individuals using wheelchairs and canes. Broadview Police officers were also on the scene.

96. At around 10:00 a.m. that morning, 20-30 federal agents parked their vehicles in

the parking lot on the opposite side of the street from the facility and began to walk across the

street toward the ICE facility. The agents were dressed in camouflage tactical gear and had masks

covering their faces. According to the Broadview Police Chief in a sworn declaration, “September

12 was the first day that I recall seeing federal agents on scene dressed in that manner. It was a

very noticeable shift in my mind.”

97. As agents approached, masked and dressed in tactical gear, the tone of the crowd

of protestors changed. The crowd grew louder and began to press closer to the building. Broadview

Police officers positioned themselves on the public way, between the 1930 Beach Street building

and the crowd, attempting to keep the crowd on the public way and off of the DHS property. When

the masked, camouflaged federal agents went into the building, the crowd calmed down, and

Broadview Police officers relocated to the outer perimeter of the crowd.

98. Also, that day, federal agents with long guns appeared on the roof of the facility.

Throughout that day, the crowd of protestors loudly chanted, and some individuals stood in the

driveway to the building as ICE vehicles attempted to enter and exit the premises, transporting

detainees. ICE assembled their own Special Weapons and Tactics (SWAT) team or Special

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Reaction Team (SRT) to respond to the protestors. ICE agents intermittently grabbed people,

physically moving them out of the driveway leading into the parking lot of the ICE facility. DHS

at some point began to use tear gas and pepper spray against the crowd.

99. That scene has recurred outside the ICE processing facility in Broadview, with DHS

agents consistently appearing armed, in tactical gear and masked, including several on the rooftop,

regularly deploying chemical munitions at protestors, along with other abusive tactics.

100. According to the sworn statement of the Broadview police chief who witnessed this

conduct daily, the “use of chemical agents by federal agents at the ICE facility in Broadview has

often been arbitrary and indiscriminate. At times it is used when the crowd is as small as ten people.

The deployment of chemical agents is dangerous to the health of both demonstrators and first

responders on the scene. In addition, when ICE agents deploy chemical agents, it causes the crowd

of protesters to disperse, sometimes running into the road, which is dangerous both for them and

for motorists. Broadview police officers have had to attempt to position themselves in a way that

directs the crowd to disperse in a safe manner. Over the course of my career in law enforcement,

the way in which federal agents have indiscriminately used chemical agents in Broadview is unlike

anything I have seen before.”

101. The Mayor of Broadview sent DHS a letter on September 26, demanding they cease

and desist that conduct. She decried the “relentless deployment of tear gas, pepper spray, mace,

and rubber bullets” by DHS agents against protesters. She wrote that ICE’s response to protesters

exercising their First Amendment rights outside the Broadview facility is “endangering nearby

village residents” and harming Broadview’s police and firefighters. “In effect, you are making

war on my community,” she wrote. “And it has to stop.”

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102. The same day, ICE Acting Director Todd Lyons wrote back to the Mayor of

Broadview. Lyons threatened Mayor Thompson and suggested that ICE’s behavior was retaliatory

for Broadview’s compliance with Illinois’ TRUST Act, stating: “[f]ailure to help provide relief [to

ICE agents from protest activities] makes you a party to the obstruction of justice . . . The only

siege in Broadview is the one being waged against the United States government. You can either

continue to be part of the problem or choose to be part of the solution by directing your police to

enforce local ordinances and working with us to remove violent offenders.”

103. According to a sworn statement by the Broadview Police Chief, the next morning,

Saturday, September 27, Bovino and several CBP agents came to the Broadview Police station.

They told the Broadview Police that the DHS agents would bring a “shitshow” to Broadview that

weekend, including that they would be increasing deployment of chemical arms, such as tear gas

and pepper spray.

104. As it had promised, DHS continued to employ those tactics outside Broadview,

including indiscriminately using those weapons on peaceful protesters, members of the media, and

legal observers. Late on Sunday morning, September 28, 2025, a CBS News Chicago reporter

stated that she was alone, driving her truck to the facility, when a masked federal agent shot a

pepper ball at her from about 50 feet inside the fence. There were no protests or protesters on scene

at the time. The attack caused the chemical agent to fill the inside of her truck, leaving white

residue on her windshield and causing her face to feel “on fire for at least the last 10 minutes or

so,” as well as causing her to vomit.

105. The Broadview Police Department now has an open criminal investigation into the

chemical munitions attack by an as-yet-unidentified ICE or CBP agent at the Broadview facility.

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106. As this DHS show of force in Broadview was escalating, CBP appeared in tactical

gear with large weapons in hand around the City of Chicago. On September 25, 2025, Greg

Bovino, head of the CBP operations in Chicago, led a small fleet of “Border Patrol” boats

downtown on the Chicago River, with officers armed with semi-automatic rifles. Photographs in

the local news showed the boats passing the upscale Riverwalk, in the area of the Trump Tower:

107. The CBP boats were seen again on the Chicago River in the following days,

seemingly doing nothing more than eponymous showboating.

108. However, the day after the Border Protection’s first unimpeded river fleet cruise,

DHS executed a memo expressing an urgent need for support in Illinois from the “Department of

War.” Specifically, on September 26, DHS requested from DoD 100 troops to protect ICE facilities

in Illinois with “immediate and sustained assistance” because of a fictional “coordinated assault

by violent groups . . . actively aligned with designated domestic terror organizations . . . .” DoD’s

National Guard Bureau informally made this request to Illinois for its National Guard troops on

September 27, which Illinois refused the following day.

109. Two days after this request, on Sunday, September 28, around 100 DHS agents,

dressed in militaristic tactical gear and carrying semi-automatic rifles, patrolled the Chicago

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business district near Millenium Park and Michigan Avenue. They positioned themselves in large

groups on major pedestrian thoroughfares in tourist and commercial areas.

110. Following that provocative display of heavily armed DHS resources and, because

of their conduct against protestors, including use of chemical munitions, Illinois State Police

(“ISP”) became involved in coordinating public safety measures at the Broadview facility.

111. At the request of Broadview Police Department (“BPD”), on October 2, 2025, the

ISP, the Cook County Sheriff’s Office, the Cook County Department of Emergency Management

and Regional Security, and the Illinois Emergency Management Agency, engaged to form a joint

operation outside the Broadview ICE facility. This included putting barricades in place around a

street near the facility to establish designated free speech protest areas off of the public road and a

few blocks from the ICE facility. It also included staffing the location with ISP troopers.

112. On October 3rd, 2025, Kristi Noem, the United States Secretary of Homeland

Security, orchestrated a visit to the Broadview facility designed to provoke those who could hear

or see the visit. Throughout this visit, rather than avoiding the protesters, Secretary Noem and her

entourage, including Bovino, entered areas congested with protesters, even when there were

alternative routes that would have avoided those areas.

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113. Defendant Noem was videotaped speaking to assembled DHS agents about

protestors outside of the ICE facility in which she stated: “Today, when we leave here we’re going

to go hard. We’re going to hammer these guys that are advocating for violence against the

American people . . . we’re going to go out there and we’re going to make sure that there’s

consequences for the way that they’re behaving and that we’re going to prosecute them” Noem’s

comments about protestors “advocating for violence against the American people” are unsupported

by public reports, and appear to conflate the First Amendment-protected speech of protestors with

political violence.

114. Noem then introduced Bovino, who began his speech saying, “It’s roll up time here,

state instrument is a hard power, you’re going to be put into full effect.” Although at that time

demonstrators were confined to a free speech area blocks from the ICE facility, and managed by

ISP and local police, Bovino called demonstrators an “unsafe crowd.” He further stated, “we’re

going to roll them all the way out of here, and when they resist what happens? They get arrested.

So it’s now going to be a free arrest zone . . . I’m giving them one warning . . . They’re getting it

here as soon as we leave.”

115. Subsequently, Secretary Noem’s motorcade, in a large armored, tactical vehicle

known as a BearCat, exited the facility through an entrance congested with protesters, rather than

the alternative, which was not. She then proceeded to an area with protesters on all sides and exited

the vehicle. Because she affirmatively went to the protest area, the U.S. Secret Service was

required to extend the protective perimeter, resulting in federal agents engaging with protesters

and prompting ISP involvement. There was no legitimate purpose under federal law for this

conduct by defendant Noem.

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116. At the protests that day outside Broadview, ISP and local police made a total of five

arrests. Upon information and belief, federal agents also made arrests. Despite the provocative

actions of Noem and DHS, the actions of protestors were managed with a routine law enforcement

response.

117. During this period, the Trump administration’s decrying of Illinois and its

leadership continued. A September 26, 2025, White House press release, titled “Democrats’

Unhinged Crusade Against ICE Fuels Bloodshed” listed dozens of federal, state and local political

figures who had made statements critical of ICE’s activities, including many Illinois elected

officials: Governor Pritzker, Chicago Mayor Brandon Johnston, Rep. Robin Kelly, Rep. Delia

Ramirez, and Rep. Nikki Budzinski.

118. The release falsely called these officials’ protected First Amendment speech part of

“a wave of Radical Left terror” and a “battle cry for violence.” This allegation of “terror” to

describe Democratic elected officials exercising their free speech rights seemed intended to

connect with Trump’s September 22nd Executive Order, Designating ANTIFA as a Domestic

Terrorist Organization.

119. On September 26, the White House issued National Security Presidential

Memorandum 7, which similarly characterized political opposition to ICE and criticisms of

fascism and authoritarianism as violent incitement and terroristic activity.

120. A few days later, on September 30 at the Pentagon, Trump and Hegseth addressed

a gathering of about 800 top military leaders. Trump took the opportunity again to attack Chicago,

stating: “You know, the Democrats run most of the cities that are in bad shape. We have many

cities in great shape too, by the way. I want you to know that. But it seems that the ones that are

run by the radical left Democrats, what they've done to San Francisco, Chicago, New York, Los

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Angeles, they're very unsafe places and we're going to straighten them out one by one.” He went

on to say, “And this is going to be a major part for some of the people in this room. That's a war

too. It's a war from within.”

121. Trump then stated that he had informed defendant Hegseth, “we should use some

of these dangerous cities as training grounds for our military National Guard, but military, because

we're going into Chicago very soon.” Defendant Hegseth has now taken formal action to do so.

II. The Trump Administration’s Unlawful Deployment of National Guard

122. The first formal step of the deployment at issue in this complaint occurred on that

same day, September 26, 2025, with a memo from DHS to DoD (“September 26 DHS memo” or

“DHS memo”).

123. Presumably referring to the ICE facility in Broadview, the DHS memo asked DoD

for 100 troops to protect ICE “facilities” in Illinois with “immediate and sustained assistance”

because of a purported but fictional “coordinated assault by violent groups . . . actively aligned

with designated domestic terror organizations . . . .”

124. The DHS memo was sent by email directly to a member of the Illinois National

Guard (ILNG) on September 29, 2025. The DHS memo specifically requests troops for the task

of “mission security in complex urban environments[,]” stating that the troops “would integrate

with federal law enforcement operations, serving in direct support of federal facility protection,

access control, and crowd control measures.”

125. No next step occurred with respect to Illinois for another week, as the Trump

administration appeared to focus on ordering the federalization of Oregon’s National Guard, as

described further below.

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126. Then, the morning of October 4th, the Adjutant General of the Illinois National

Guard, General Rodney C. Boyd, received by email a formal memorandum from the National

Guard Bureau of the U.S. Department of Defense (“October 4, 2025 National Guard Bureau

Memo” or “National Guard Bureau Memo”). The National Guard Bureau Memo and email at

10:23 a.m. that morning, bore the subject, “Request for Illinois National Guard Federal Protection

Mission.” It stated: “I am writing to inform you that the President has directed the mobilization of

at least 300 members of the Illinois National Guard (ILNG) to protect federal personnel, functions,

and property in Illinois.” It provided no further information about the specifics of the intended

deployment, nor any order or memorandum from the President.

127. The National Guard Bureau memo further explicitly stated that if the “request” for

300 troops was not acceded to within two hours, defendant Hegseth would federalize and deploy

under Title 10 status as many Illinois National Guard troops as he chose. Specifically, it stated:

“Due to the circumstances and immediate nature of this requirement, if ILNG forces are not

mobilized under Title 32 in the next 2 hours, the Secretary of War will direct the mobilization of

as many members of the ILNG as he may deem necessary under Title 10 United States Code.” The

National Guard Bureau memo offered thanks for support in an “emergent situation,” without

providing any legal citation or factual support.

128. The National Guard Bureau memo further stated: “If your Governor agrees to a

Title 32 mobilization of the ILNG, we will work with the Department of Homeland Security and

other federal officials to coordinate mission details with you. To be clear, we believe time is of the

essence and failure to mobilize sufficient forces quickly to address the situation may risk lives and

property damage. I respectfully request that you inform me immediately if your Governor is unable

or unwilling to mobilize the ILNG under Title 32 to perform the necessary protective functions.”

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Governor Pritzker’s office received no direct request or memorandum from any of the defendants

regarding a Title 32 National Guard mobilization request at any time.

129. General Boyd responded to the National Guard Bureau memo in the early afternoon

by email, stating: “The Governor will not call National Guard troops into Title 32 status. There is

no public safety need or other emergency requiring the National Guard and, therefore, the

Governor objects to the federalization of the National Guard.”

130. The evening of October 4, General Boyd received a memorandum from defendant

Hegseth, purporting to call Illinois National Guard into federal service pursuant to 10 U.S.C. §

12406 (the “Federalization Oder”). The Federalization Order, purporting to overrule the objection

of the Governor of Illinois to bring Illinois’s National Guard into the service of the Trump

administration, had only two paragraphs, as shown below.

131. The memo’s only language indicating its basis for invoking Section 12406 was its

purpose to “protect [ICE], Federal Protective Service, and other U.S. Government personnel who

are performing federal functions, including the enforcement of Federal law, and to protect Federal

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property, at locations where violent demonstrations against these functions are occurring or are

likely to occur based on current threat assessments and planned operations.” It provided no

information about either the “threat assessments” or “planned operations” referenced in the

memorandum, or the basis for the assertion that violent demonstrations would be “likely” based

on either. Its only citation to authority of any kind is its reference to unspecified “President’s

direction.”

132. The Federalization Order from defendant Hegseth neither cited nor attached any

order from the President invoking Section 12406, as required by law.

133. On October 5, General Boyd of the Illinois National Guard learned of and received

another memorandum, purporting to invoke Section 12406 to federalize national guard troops from

the State of Texas into Illinois and Oregon (“the Texas Mobilization Order”). The Texas

Mobilization Order was an undated memorandum from defendant Hegseth that, similar to that

issued the prior weekend in Oregon, referenced the June 7 Presidential memorandum that had been

used as support for the federalization of California’s National Guard months prior.

134. The Texas Mobilization Order stated that, on October 4, 2025, “the President had

determined that violent incidents, as well as the credible threat of continued violence, are impeding

the execution of the laws of the United States in Illinois, Oregon, and other locations throughout

the United States.” It purported to authorize, pursuant to 10 U.S.C. § 12406, up to 400 Texas

National Guard troops for an initial period of 60 days, subject to extension, “to perform federal

protection missions where needed, including in the cities of Chicago and Portland.”

135. Despite referencing an October 4, 2025 Presidential determination as the basis for

its action, the Texas Mobilization Order provided no order from the President for the extraordinary

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action. The State of Illinois learned from a credible source that the physical deployment of the

Texas National Guard troops to Illinois was planned for the following day, October 6th.

III. The Trump Administration’s Wave of Domestic Troop Deployments

136. Defendants’ unlawful deployment of the Illinois National Guard, over the objection

of the state, is similar to the unlawful course of conduct they have taken against other disfavored

states and cities. Prior to the Federalization Order and Texas mobilization order regarding

deployment in Illinois, defendants federalized National Guard troops in California, Washington,

D.C., and Oregon over the objection of each of their leaders. No circumstances in any of these

jurisdictions warranted federalization of troops under Section 12406, but each has “sanctuary”

laws, Democratic leadership, and has been the subject of Trump’s taunts about “crime.” Each of

them, including Chicago and Illinois, is being targeted for this harmful and coercive conduct by

defendants.

137. In his first troop deployment in Los Angeles, Trump’s federalization of the

California National Guard on June 7, 2025, followed by only one day the beginning of aggressive

immigration enforcement activity in the vicinity. The immigration enforcement tactics inspired

community outrage and protest response. President Trump’s June 7 authorizing memorandum to

defendants Hegseth, Noem, and Bondi cited 10 U.S.C. § 12406 as legal authority for federalizing

the California National Guard and claimed, as his factual basis, violence, disorder, and damage to

federal property, as follows:

Numerous incidents of violence and disorder have recently occurred

and threaten to continue in response to the enforcement of Federal
law by U.S. Immigration and Customs Enforcement (ICE) and other
United States Government personnel who are performing Federal
functions and supporting the faithful execution of Federal
immigration laws. In addition, violent protests threaten the security
of and significant damage to Federal immigration detention facilities
and other Federal property.

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138. California challenged that deployment in court. On September 2, 2025, the federal

court in California found that the Trump administration had “instigated a months-long deployment

of the National Guard and Marines to Los Angeles for the purpose of establishing a military

presence there and enforcing federal law. Such conduct is a serious violation of the Posse

Comitatus Act.” Newsom v. Trump, 3:25-cv-04870-CRB, 2025 WL 2501619, at *43 (N.D. Cal.

Sept. 2, 2025), appeal docketed, No. 25-5553 (9th Cir. Sept. 3, 2025). That decision is now stayed

while on appeal.

139. With California National Guard two months into their Los Angeles area

deployment, on August 11, the Trump administration’s focus turned to Washington, D.C. At a

press conference at the White House that day, President Trump announced the planned deployment

of the D.C. National Guard into the district to “to rescue our nation’s Capitol from crime,

bloodshed, bedlam and squalor and worse.” He called it “liberation day in DC,” and said, “we’re

gonna take our Capitol back.”

140. At the same briefing, defendant Hegseth announced that day that National Guard

troops would be deployed in D.C. to “stand with their law enforcement partners”—which, he said,

was the “same thing” the National Guard did in Los Angeles. The Trump administration deployed

National Guard troops from D.C. and seven other states into that city.

141. On September 4, 2025, the District of Columbia sued the Trump Administration for

violating various statutes as well as the U.S. Constitution. D.C. alleged that, among other harms,

the “encroachment of National Guard troops in the District has also already caused harm to public

safety in the District.” Compl. at. ¶¶ 129-30, District of Columbia v. Trump, No. 25 C 3005 (D.

D.C. Sept. 4, 2025).

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142. On September 28, 2025, the Trump administration announced the federalization of

the Oregon National Guard over the Oregon Governor’s objection. With a two-paragraph cover

memo, only one paragraph of which even regarded Oregon, the “Secretary of War” sent a

“MEMORANDUM FOR THE ADJUTANT GENERAL, OREGON NATIONAL GUARD

THROUGH: THE GOVERNOR OF OREGON” with the “SUBJECT: Calling Members of the

Oregon National Guard into Federal Service[.]”

143. The first paragraph of the September 28 memorandum to Oregon’s Adjutant

General referenced the June 7 memo that had been used for federalizing the California National

Guard, and it attached that June 7 memo.

144. In remarkable similarity to the October 4 memorandum received by Illinois, the

September 28 Oregon memorandum stated only directives without any specific basis for the

federalization of the Oregon National Guard, as follows:

This memorandum further implements the President's direction. 200 members of

the Oregon National Guard will be called into Federal service effective immediately
for a period of 60 days. The Chief of the National Guard Bureau will immediately
coordinate the details of the mobilization with you, in coordination with the
Chairman of the Joint Chiefs of Staff and Commander, U.S. Northern Command.
The mobilized Service members will be under the command and control of the
Commander, U.S. Northern Command.

145. Oregon promptly filed suit to prevent this unlawful conduct. On October 4, 2025,

a federal district court granted Oregon’s motion for a temporary restraining order and held that

plaintiffs in that case were “likely to succeed on their claim that the President’s federalization of

the Oregon National Guard exceeded his statutory authority under 10 U.S.C. § 12406 was ultra

vires”, and also exceeded the President’s “constitutional authority and violated the Tenth

Amendment.” Oregon v. Trump, No. 3:25-cv-1756-IM, at 16 (D. Or. Oct. 4, 2025).

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146. The Oregon court recognized that, “This case involves the intersection of three of

the most fundamental principles in our constitutional democracy. The first concerns the

relationship between the federal government and the states. The second concerns the relationship

between the United States armed forces and domestic law enforcement. The third concerns the

proper role of the judicial branch in ensuring that the executive branch complies with the laws and

limitations imposed by the legislative branch. Whether we choose to follow what the Constitution

mandates with respect to these three relationships goes to the heart of what it means to live under

the rule of law in the United States.” Id. at 2.

147. On these questions, the court concluded that: “this country has a longstanding and

foundational tradition of resistance to government overreach, especially in the form of military

intrusion into civil affairs . . . . This historical tradition boils down to a simple proposition: this is

a nation of Constitutional law, not martial law. Defendants have made a range of arguments that,

if accepted, risk blurring the line between civil and military federal power—to the detriment of

this nation.” Id. at 30.

148. However, even as that court entered its temporary restraining order against the

defendants on October 4, 2025, the Trump administration ordered the redeployment of hundreds

of the federalized California National guard troops from California to Oregon, without the consent

of the Governor of Oregon. The Texas mobilization order also seeks to send Texas National Guard

to Oregon, in addition to Illinois. This appears to be a clear end-run effort around the Oregon

district court’s temporary restraining order preventing defendants from federalizing the Oregon

National Guard for deployment in Oregon.

149. Oregon filed an emergency motion to enjoin those efforts. At an October 5

emergency hearing before the court, the district judge enjoined both new deployment orders, in

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which defendant Hegseth, on behalf of the Trump administration, had sought to deploy other states’

National Guard to Oregon.

150. As defendants have made clear, the Trump administration’s troop deployment plan

in Illinois is simply a continuation of the administration’s militaristic vision of troops deployed

across the country. That deployment in Illinois follows a pattern of involuntary National Guard

deployment in four other jurisdictions is further evidence that defendants’ actions are not based on

the facts on the ground in Illinois or the needs of federal law enforcement here and are, accordingly,

unlawful.

IV. No Factual or Legal Predicate Exists for Deploying the Military in Illinois

151. When Trump was articulating his plans to send troops to Chicago on August 22nd,

Governor Pritzker responded the next day that, “There is no emergency that warrants the President

of the United States federalizing the Illinois National Guard” or sending in federal agents.

152. There is no insurrection in Illinois.

153. There is no rebellion in Illinois.

154. The federal government is able to enforce federal law in Illinois.

155. The manufactured nature of the crisis is clear. Trump first announced his plans to

send National Guard troops to Chicago from the Oval Office on August 22, 2025. His rationale

then, as at many points, was his view of Chicago and Illinois as crime ridden. At that event, he

asserted that his national guard deployment in Washington D.C. had reduced crime and he wanted

to send troops in Chicago for the same reason.

156. Trump stated: “National Guard has done such an incredible job working with the

police and we haven’t had to bring in the -- the regular military which we’re willing to do if we

have to. And after we do this, we'll go to another location and we’ll make it safe also. We’re going

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to make our country very safe. We’re going to make our cities very, very safe. Chicago’s a mess.

You have an incompetent mayor, grossly incompetent and we'll straighten that one out probably

next. That’ll be our next one after this and it won’t even be tough.”

157. Therefore, this decision was made long before recent events, and Trump’s true plan

is impermissibly to use federalized national guard as a crime-fighting force.

158. As recently as yesterday, Trump again made clear that his purpose in sending troops

to Chicago is to fight crime. On October 5, 2025, President Trump addressed reporters in front of

Marine One, spoke about crime in Chicago, and said of the city, “they need help.” He then claimed

that he had “solved the crime” in Washington D.C., where he previously had sent troops, and said

“we’re going to do that in Chicago.”

159. Additionally, as explained above, any assertion that the facts in Illinois require this

extraordinary step is also belied by the fact that defendants have used the same playbook of

involuntary deployment of the National Guard in four other jurisdictions in just the last few

months.

160. In fact, DHS’s first formal memo seeking the deployment of National Guard troops

in Illinois, dated September 26, 2025, claimed an urgent need because of “lawless riots.” That

assertion was plainly untrue, as evidenced by the fact that no further steps to deploy the National

Guard occurred for more than a week, until the morning of October 4, 2025.

161. Now, the Federalization Order claims that DHS needs 300 military members to

protect ICE’s “federal facilities” in Illinois, and the Secretary of Defense offers Illinois National

Guard members for that task. What facilities, for what purpose, and under what authority none of

the memos say.

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162. ICE has no detention facilities in Illinois, according to its own website. It has

exactly one “processing” center, in Broadview. Otherwise, its only “facilities” in the state of

Illinois are three office locations.

163. DHS’s claim that the request for military intervention is made because of “lawless

riots” or its claim that the request is to “protect federal facilities” suggest that it could be relying

on the existence of protests outside the single ICE processing facility in Broadview. However, far

from lawless riots, the Broadview protests have been small, primarily peaceful, and unfortunately

escalated by DHS’s own conduct, seemingly for the goal of using them as a pretext for the Chicago

troop deployment that was announced by Trump long ago.

164. Although Illinois State Police regularly partners with federal law enforcement on

criminal matters, the only requests made to ISP from DHS relating to the Broadview facility were

from DHS’s Homeland Security Investigations (HSI), and ISP responded to each of them. One

concerned an arrested protester in possession of a firearm; ISP clarified that the protester had a

valid Firearm Owner Identification card and Concealed Carry Permit. The second involved traffic

management for a potential protest, and the third was a request for ISP’s video of the area

surrounding the ICE facility. When ISP ultimately joined the joint unified command, it was not

because of any need for support or help from DHS, but instead to support Broadview Police.

165. Therefore, the limited protest activity also has not prevented the Trump

administration from enforcing federal laws.

166. Defendant DHS has loudly touted its immigration enforcement success in

Operation “Midway Blitz”. In an October 3rd press release regarding the operation’s success,

DHS wrote that ICE and CBP “have arrested more than 1,000 illegal aliens.” Even before the

“blitz,” ICE’s Illinois law enforcement activity in 2025 was up by a significant factor, and

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immigration detentions had more than doubled, according to September 12, 2025 WBEZ reporting

based on collected data for January through July of 2024 and 2025.

167. News reports about DHS’s activities in the area also make clear they are able to

enforce federal law.

168. On September 16, 2025, defendant Noem came in person to suburban Illinois to

oversee a DHS raid on a home that included helicopters and many federal agents breaking down

the door of a U.S. citizen’s home in Elgin, Illinois, without presentation of a warrant. According

to a local report, the “entire street was blocked off by armed ICE agents wearing fatigues and using

military vehicles[,]” and “helicopters, bright lights and smoke bombs were used in the raid.”

169. According to reporting by WBEZ and other news outlets, during the raid overseen

by Noem, DHS detained several occupants of the home, including two U.S. citizens. Tricia

McLaughlin, DHS Assistant Secretary, posted on social media that day to tout several arrests ICE

had made that morning “so far” in the Chicago area.

170. On September 19, 2025, DHS’s official social media account on X, @DHSgov,

reposted a local news video showing an ICE agent outside the ICE facility Broadview violently

throwing to the ground a Congressional candidate who had been there to protest the detention

conditions. The posted stated: “You will not stop @ICEgov and DHS law enforcement from

enforcing our immigration laws[.]”

171. On September 25, 2025, CBP was seen using four boats with armed agents

positioned on them traveling up and down the Chicago River in the Loop. CBP Chief Michael W.

Banks posted several photos of this event, including several posed to highlight boats against the

Trump Tower’s marquee, with the caption “Where streets end, our Marine Unit begins. On the

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Chicago River, CBP leadership stays vigilant. Our ability to patrol on the water extends the reach

of enforcement.”

172. The next day, September 26th—the same day as DHS’s memo expressing a

purported need for 100 National Guard troops —DHS continued to make clear that demonstrations

and protests have not had any impact on their ability to carry out their mission. That day, DHS

issued a press release titled, “DHS Is Fighting Back Against Antifa Violence,” with the subheading

“Antifa-aligned domestic terrorists have nowhere to hide: DHS is upholding the rule of law.”

173. The September 26 press release focused on DHS’s success in its mission and then

set out a series of reports of arrests made and charges filed against those it considered as seeking

to get in DHS’s way, including in Broadview, Illinois. The release made clear that: “Antifa and

their friends haven’t stopped us. They’re not even slowing us down.”

174. On September 27, 2025, after Bovino and DHS agents had visited the Broadview

Police Department in the morning, as described above, Bovino and other DHS agents in tactical

gear were seen marching freely through the streets adjoining the Broadview ICE facility, entering

and exiting the fencing that they erected surrounding the facility. At times when individual

demonstrators temporarily obstructed traffic in the right-of-way, DHS appeared able to clear

vehicle passage.

175. At some point late in the night of September 27, DHS officials outside the ICE

facility in Broadview formed a line and marched north on one of two available streets DHS could

use to exit the building, Beach Street, pushing the crowd up the street and forcing them to relocate

to Lexington Avenue. That evening, those agents also deployed chemical munitions, including tear

gas, pepper spray, and pepper bullets at the protesters.

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176. Based upon what DHS agents told the Broadview Police Chief the next morning,

as relayed in his sworn declaration, on the night of September 27, DHS agents detained eleven

protesters. According to a September 29 press release from the U.S. Attorney’s Office for the

Northern District of Illinois, five protesters were charged with federal offenses. Federal law

continued, and continues, to be enforced in Illinois.

177. In addition, dozens of DHS agents dressed in tactical gear and carrying semi-

automatic rifles walked the streets of downtown Chicago on September 28. Their presence on the

streets was a demonstration of force. And that confident show of force in downtown Chicago

makes clear that the statutory basis for Title 10 has not been met.

178. On September 29, CBP Commander-at-Large Bovino, the head of the “blitz,” led

more than 300 agents in raiding a large apartment building on the south side of Chicago. As part

of the operation, agents rappelled down to the building from Blackhawk helicopters among other

military style tactics. While it is not clear whether any part of that conduct was within any lawful

federal authority, defendants were not impeded in executing this large-scale planned operation.

179. Following the operation that night, in a video recorded interview at the site of the

apartment raid, Bovino stridently directed a message at Governor Pritzker, “Don’t worry, Governor

Pritzker, we’ve got it covered from here. This is just the beginning… We’re gonna roll on and on.

We’re gonna turn and burn, Governor. We’re going from this one to the next to the next to the

next.”

180. Also, that same day, the Trump administration asserted that it can and would

enforce federal law and, where it perceives the need, it would assign additional federal law

enforcement, components of DOJ, to assist DHS. On September 29, Attorney General Bondi

issued a memo titled, ENDING POLITICAL VIOLENCE AGAINST ICE. It decried a new era of

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political violence and cited incidents such as the Dallas shooting at an ICE facility, as well as the

non-ICE-related killing of Charlie Kirk. The memo included misleading descriptions of the

protests outside Broadview in the days just before, over the weekend of September 26-28.

181. Leaving aside the disputed predicate of the memo, the document makes clear that

DOJ is fully capable of enforcing federal law. It states, in part: “The Department of Justice will

stand strong when federal law enforcement officers are attacked or threatened for doing their sworn

duty on behalf of the United States government. I am directing the Bureau of Alcohol, Tobacco,

Firearms and Explosives, the United States Marshals Service, the Drug Enforcement

Administration, and the Federal Bureau of Investigation to immediately direct all necessary

officers and agents to defend ICE facilities and personnel whenever and wherever they come under

attack, including in Portland and Chicago.”

182. Upon information and belief, DOJ already had assigned agents from these

components to provide support to DHS and has been continuing to do so since issuing the

September 29 Bondi memo. Plaintiffs are not aware of any other federal agencies providing

support similar to what DOJ offered in the Bondi memo, although most, if not every, other federal

agency also has sworn officers and agents as well and could do the same.

V. The Federalized National Guard Deployment Harms Illinois

A. The State’s Sovereign Interests are Injured

183. Illinois’s sovereignty is harmed by this unlawful incursion by the infringement of

its sovereign interest in managing law enforcement within its own borders, including the authority

to manage protests and unrest.

184. The police powers reserved to the State of Illinois includes the authority to regulate

its internal law enforcement activities. United States v. Morrison, 529 U.S. 598, 618 (2000).

Likewise, those powers include the work of policing its own populace.
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185. Defendants’ efforts to overtake the state’s authority in this regard functionally

supersedes Illinois’s authority to regulate and oversee its own local and state law enforcement. It

reflects an unconstitutional attempt to infringe on Illinois’s power.

186. The Federalization Order and the implementing agency actions also injure Illinois’s

abilities to give full effect to its own laws protecting residents’ health, safety, and rights, harming

its sovereign interests and intruding on an area traditionally left to the States.

187. Defendants’ purported use of National Guard troops to control protests or guard

property amounts to a usurpation of the role of domestic law enforcement. The state has neither

requested nor consented to federal intervention to take over that law enforcement role, which is

being carried out by local enforcement under their lawful authority. The impending use of

federalized troops to engage in domestic law enforcement, without the State’s consent, threatens

an irreparable injury to Illinois’s sovereign interest in managing its own law enforcement activities.

188. Defendants’ conduct also will directly and concretely interfere with current and

planned law enforcement activities of state and local authorities. State and local law enforcement

agencies, including variously the Broadview Police Department, the Cook County Sheriff’s Office,

the Chicago Police Department, and the Illinois State Police, along with other municipal police

forces who provide support to these departments and each other when necessary through mutual

aid agreements, have in place their own plans and protocols for maintaining safety and order in

Illinois communities. They are trained and resourced to execute those plans, including in

coordination with each other, and do so regularly.

189. The unlawful deployment of federalized National Guard troops to usurp that law

enforcement role will directly interfere with the ability of state and local law enforcement to deal

with any given situation. The presence of military units purporting to exercise law enforcement

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authority creates confusion among the public and threatens to undermine the work of local law

enforcement in maintaining order and combating local crime. This is especially concerning as

numerous state and local law enforcement and community initiatives in the past years have been

implemented, leading to a significant reduction in crime in the State and City of Chicago.

190. Further, military troops are not law enforcement. They are not trained in law

enforcement in the professional manner that Plaintiffs’ own law enforcement are trained for the

role of constitutional policing, including property protection and crowd control during protest

activity, along with other domestic law enforcement responsibilities. As explained above, the

needless presence of federalized troops will lead directly to escalated tensions and increased

protest activity, interfering with state and local law enforcement’s ability to maintain order. It will

require diversion of state and local law enforcement and state and local resources.

191. Recent deployment of troops elsewhere in the country have provoked protests and

escalated tensions. Those military incursions included operations that were directly calculated as

shows of force, intended to demonstrate federal presence and strength in otherwise peaceful

locations. See Newsom, 2025 WL 2501619 at *7 (describing federal troops stationed in Humvees

and tactical vehicles outside MacArthur Park in Los Angeles). As in those instances, Defendants’

deployment of troops in Illinois communities will provoke and escalate protests and unrest and

will require the State to divert its law enforcement personnel and resources to deal with unrest that

the federal military presence has created.

192. In addition to the sovereign injury to Illinois, Plaintiffs are harmed in multiple other

ways by defendants’ unlawful conduct.

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B. The Diversion of National Guard Personnel, Rendering them Unable to

Engage in Other Critical Work, Harms the State of Illinois.

193. Defendants’ unlawful federalization and deployment of the Illinois National Guard

will concretely harm the State’s interests by rendering those members unable to engage in other

critical work.

194. Illinois National Guard (ILNG) members are trained to carry out important

missions, where necessary, and at great cost, both to themselves personally and to the state. Most

ILNG members are part time reservists who have civilian jobs. They commit a minimum of one

weekend per month and two additional weeks per year, primarily for training and maintaining unit

readiness.

195. Except for when it has been lawfully called into federal service, ILNG answers to

its Commander-in-Chief, the Governor of Illinois. The Governor calls members of the ILNG into

active duty to serve the needs of Illinois in numerous ways, including to assist with emergent and

unpredictable situations the State could face at any moment. The Governor, in consultation with

other state government officials and local law enforcement, is in the best position to determine the

needs of the State and how the Guard could be deployed to meet those needs.

196. The Illinois National Guard’s resources are limited. While the ILNG has about

12,775 total members, only some of those are presently available for assignment over the next six

months. Others are unavailable because, among other reasons, they are already deployed in federal

services overseas or at military bases in the United States; engaged in the ILNG’s essential

administrative functions; or in basic training. Unlawfully federalizing even a portion of these

Guard members impairs the State’s capacity to respond to emergencies.

197. Since September 11, 2001, ILNG members have faced an increased operations

tempo that has included longer training periods in more advanced specialties. For example, ILNG

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members recently completed an annual training on how to respond to cyberattacks. They

specifically perform work to protect Illinois’s elections infrastructure from cyberattacks and other

intrusions.

198. They also recently performed training on response to chemical and biological

weapons attacks, as well as on responding to man-made and natural disasters, including site search,

rescue, mass decontamination, medical triage, and fatality recovery.

199. In its role as a state entity, ILNG also has been called into state active duty to

respond to disasters including several instances of severe flooding in the state, as well as severe

winter weather. And it has provided significant planning and support for large-scale events, like

the Democratic National Convention in 2024, which hosted 50,000 people.

200. With a federal deployment of ILNG members, the State does not have the benefit

of all of its ILNG members, including if needed by the State for emergency response efforts. Given

the ILNG’s limited resources, and the inherent uncertainty about what needs might arise,

needlessly calling hundreds of the ILNG’s members into federal service for a months-long period

places Illinois in jeopardy.

C. The Federal Deployment Will Harm Plaintiffs’ Ability to Provide Important

Services to the Community

201. The deployment of federalized national guard troops into Illinois will cause great

and immediate harm. This harm will occur to Plaintiffs regardless of whether the deployment is

of Illinois National Guard or another military.

202. In addition to the above harms, a deployment will hinder the provision of needed

social services and health care and redirect valuable resources away from their proper use on behalf

of the City of Chicago and the State.

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203. Among other harms and impacts on resources, the City of Chicago’s Office of

Emergency Management & Communications will have to divert important resources away from

needed services and planning as a result of any troop deployment in the greater Chicago area.

204. The Chicago Police Department (“CPD”) has likewise incurred substantial costs

protecting public safety at large events that generated protest activity, as a military deployment

would. For example, Chicago hosted the Democratic National Convention in 2024. In connection

with that event, CPD spent $30 million on operations, overtime compensation, and other expenses.

These costs can increase when responding to unplanned protests. For instance, in 2020, CPD spent

about $90 million responding to often-unplanned protests and civil unrest following George

Floyd’s murder.

205. Based on these facts, it is reasonably likely that the deployment of the National

Guard would impose costs on CPD and other City departments while diverting those departments’

resources away from their usual responsibilities.

D. Defendants’ Actions Will Also Harm the State of Illinois and the City of
Chicago by Suppressing Business Activity.

206. Defendants’ conduct threatens the economic well-being of the people of Illinois. In

recent months, unlawful federal deployments and militarized raids in California and the District of

Columbia have directly and rapidly chilled economic activity. The deployment of troops in

California stifled economic activity in the Los Angeles area. Restaurants, festivals, and farmers’

markets shut down, as individuals were afraid to leave their homes due to militarized raids. As the

Newsom court observed, federal immigration-enforcement actions and the deployment of the

National Guard has “sent economic shockwaves through southern California.” 2025 WL 2501619,

at *14. A study employing U.S. Census Bureau data found that federal immigration actions had

“profoundly negative consequences for California’s economy,” comparable only to the Great

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Recession and Covid-19 pandemic. Newsom v. Trump, Case No. 25-4870, Dkt. 183, Ex. 14 at 7

(N.D. Cal. Sept. 2, 2025). The number of people reporting to work in California’s private sector

decreased by 3.1% in June 2025 and by 4.9% in July 2025, even though those numbers increased

elsewhere. Id. at 1, 4. The study explained: “As a result of [federal] enforcement actions, many

noncitizens avoided work, school, and other public spaces, leading to declines in consumption,

business, work and employment.” Id. at 2. A Los Angeles Chamber of Commerce official

confirmed that the National Guard deployment harmed “small businesses throughout the region,”

explaining that businesses saw “a sharp decrease in customers,” “increased staffing shortages,”

and incurred “additional costs” for “security” and other expenses. Id., Dkt. 183-3 ¶¶ 5-9.

Attendance at public events in Los Angeles also suffered. For example, the director of an LGBTQ+

organization that holds an annual event in a predominantly Latino neighborhood stated that 2,000

fewer people attended the post-deployment event this year compared to prior years. Id., Dkt. 183-

6 ¶¶ 4, 13-14.

207. Similarly, according to reporting in the Washington Post, the deployment of

National Guard troops in the District of Columbia depressed key industries, including tourism,

restaurants, and hospitality services. Within a week after the deployment of federal troops in D.C.,

foot traffic in the District dropped 7 percent on average, with restaurant reservations showing an

even steeper drop.

208. Defendants’ military incursion into Illinois threatens similar immediate harms by

depressing business activities, travel, and tourism in Illinois communities. Chicago taxes various

sales and services. E.g., Mun. Code of Chi. §§ 3-24-030 (hotel tax), 3-30-030 (restaurant tax); 3-

40-010 (sales tax). Thus, when businesses in Chicago experience declining sales, Chicago receives

less tax revenue.

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209. Defendants’ conduct also threatens financial harm to the government of Illinois in

multiple ways. The military incursion’s chilling effect on economic activity will directly decrease

tax revenue collected by the State and by the City of Chicago. In the District of Columbia, troop

deployment has resulted in a reduction of work hours for some District workers, and a

corresponding decline in income tax withholding paid to the District government.

210. Deployment of troops in Illinois communities threatens similar harm to both City

of Chicago and State of Illinois tax revenues.

First Claim for Relief

Ultra Vires Action – Violation of 10 U.S.C. § 12406
Against All Defendants

211. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

212. Under 10 U.S.C. § 12406, only the President is permitted to federalize a state’s

National Guard, and they are only permitted to do so when (1) the United States, or any of the

Commonwealths or possessions, is invaded or is in danger of invasion by a foreign nation; (2)

there is a rebellion or danger of a rebellion against the authority of the Government of the United

States; or (3) the President is unable with the regular forces to execute the laws of the United

States. The order issued by the President pursuant to this provision must specify the basis for this

invocation, including, for subsection (3), what laws the President is unable to execute. None of

that was done here. Moreover, no factual circumstances satisfying any of those predicates are

present in Illinois. Defendants’ actions to the contrary—including in the Federalization Order and

the Texas Mobilization Order—are patently pretextual and lack any good faith basis.

213. Defendants have not identified any “invasion by a foreign nation.”

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214. Nor is there any “rebellion or danger of a rebellion.” The assertion that National

Guard troops are needed to protect federal facilities is both untrue and legally insufficient. Neither

the June 7, 2025 Presidential memorandum, nor the federalization or Texas mobilization order

identified any particular location or event as a basis for federalizing state military. However, to

the extent that protests in Broadview, Illinois, are the Defendants’ excuse for this deployment in

Illinois, they are insufficient.

215. The protests in Broadview are contained to a small area a few blocks from an ICE

facility, are being successfully managed, and do not in any way constitute a rebellion or danger of

a rebellion. Likewise, no other facts warrant a finding of rebellion in the State of Illinois.

216. Nor have Defendants cited even a single instance in which they were “unable . . .

to execute the laws of the United States” as would be required under Section 12406. For example,

they have not identified an inability to detain or deport those who are unlawfully present in the

United States due to protests in Broadview.

217. In addition, the Federalization Order and the Texas Mobilization Order contravene

Section 12406 by failing to identify the federal laws that the President purports to be unable to

execute and by failing to specify a corresponding scope of authority to execute “those laws.”

218. By ignoring these prerequisites for an invocation of 10 U.S.C. § 12406, and relying

on pretextual, baseless, and bad-faith invocation of Section 12406, Defendants are acting ultra

vires.

Second Claim for Relief

Ultra Vires Action — Violation of the Posse Comitatus Act and 10 U.S.C. § 275
Against All Defendants

219. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

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220. The Posse Comitatus Act forbids the armed forces from engaging in law

enforcement “except in cases and under circumstances expressly authorized by the Constitution or

Act of Congress.” 18 U.S.C. § 1385.

221. Consistent with the limitations imposed by the PCA, the Title 10 statutory scheme

itself expressly limits the scope of activities that can be performed by the military. For instance,

10 U.S.C. § 275 provides that “The Secretary of Defense shall prescribe such regulations as may

be necessary to ensure that any activity (including the provision of any equipment or facility or the

assignment or detail of any personnel) under this chapter does not include or permit direct

participation by a member of the Army, Navy, Air Force, or Marine Corps in a search, seizure,

arrest, or other similar activity unless participation un such activity by such member is otherwise

authorized by law.”

222. Neither the Constitution nor any Act of Congress permits Defendants to use the

armed forces, including the National Guard, for routine law enforcement, such as protest

management or the suppression of violent crime or property damage.

223. The Court need look no further than Defendants’ own statements on social media

and to United States military leaders to conclude that this troop deployment is being made for

purposes that are plainly incompatible with the Posse Comitatus Act and 10 U.S.C. § 275.

224. By ignoring the PCA and 10 U.S.C. § 275, Defendants are acting ultra vires.

Third Claim for Relief

Tenth Amendment of the U.S. Constitution
Against All Defendants

225. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

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226. The Tenth Amendment provides that “[t]he powers not delegated to the United

States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively,

or to the people.”

227. Defendants’ federalization of members of the Illinois National Guard usurps the

Governor of Illinois’s role as Commander-in-Chief of the National Guard in Illinois, which he

could and would use if necessary, and violates the State’s sovereign role over local law

enforcement, pursuant to its police powers.

228. Under our system of federalism, policing and crime control remain one of the most

basic rights reserved to the States. “Indeed, we can think of no better example of the police power,

which the Founders denied the National Government and reposed in the States, than the

suppression of violent crime and vindication of its victims.” United States v. Morrison, 529 U.S.

598, 618 (2000). “[T]he power to establish the ordinary regulations of police has been left with the

individual States and cannot be assumed by the national government.” Patterson v. State of

Kentucky, 97 U.S. 501, 503 (1878).

229. Local control of law enforcement is also essential to the protection of liberty and

government accountability. “Because the police power is controlled by 50 different States instead

of one national sovereign, the facets of governing that touch on citizens’ daily lives are normally

administered by smaller governments closer to the governed. The Framers thus ensured that

powers which ‘in the ordinary course of affairs, concern the lives, liberties, and properties of the

people’ were held by governments more local and more accountable than a distant federal

bureaucracy.” Nat’l Fed’n of Indep. Bus. v. Sebelius, 567 U.S. 519, 536 (2012) (quoting The

Federalist No. 45, at 293 (J. Madison)).

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230. The Federalization Order’s deployment of federalized military forces to protect

federal personal and property from “violent demonstrations” that “are occurring or are likely to

occur” represents the exact type of intrusion on State power that is at the heart of the Tenth

Amendment, especially where, as here, there is no evidence that local law enforcement was

incapable of asserting control and ensuring public safety. State officials in conjunction with local

officials, such as the Broadview Police Department and the Cook County Sheriff’s Department,

are in the best position to determine what resources are necessary to preserve public safety amid

protest activity, and to intervene to enforce public safety and criminal laws when warranted.

231. In addition to infringing upon the States’ police powers, Defendants’ actions in

calling up and deploying members of the Illinois National Guard are designed to coerce Illinois

into abandoning its own statutory prerogatives and instead adopt President Trump’s policy

priorities.

232. “The Federal Government may neither issue directives requiring the States to

address particular problems, nor command the States’ officers, or those of their political

subdivisions, to administer or enforce a federal regulatory program.” Printz v. United States, 521

U.S. 898, 935 (1997).

233. Similarly, the federal government “may not simply ‘commandee[r] the legislative

processes of the States by directly compelling them to enact and enforce a federal regulatory

program.’” New York v. U.S., 505 U.S. 144, 161 (1992) (quoting Hodel v. Virginia Surface Mining

& Reclamation Assn., Inc., 452 U.S. 264, 288 (1981)). Such impermissible pressure can occur

“whether Congress directly commands a State to regulate or indirectly coerces a State to adopt a

federal regulatory system as its own.” Nat’l Fed’n of Indep. Bus., 567 U.S. at 578.

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234. Defendants’ actions forced such an impermissible “choice”: use state and local law

enforcement resources to carry out the federal government’s civil immigration priorities or accept

occupation by federal troops. Then, in advance of the Federalization Order, Defendants posed an

additional coercive “choice”: either deploy the National Guard under state control or be subject

to federalization via 10 U.S.C. § 12406.

235. Additionally, Defendants’ actions place Illinois National Guard members under

federal command and control, usurping the Governor’s authority to command them and depriving

the State of Illinois of their services. These actions thus violate the Tenth Amendment because the

President lacks constitutional authority to call forth the militia in a manner that exceeds the

authority delegated to him by Congress. Indeed, Congress is granted the authority to “provide for

calling forth the Militia to execute the Laws of the Union, suppress Insurrections and repel

Invasions.” U.S. Const. art. I, § 8, cl. 15. Congress has exercised that authority through 10 U.S.C.

§ 12406 which, as explained, does not authorize Defendants’ decision to federalize the Illinois

National Guard. By acting in a manner that “exceeds the National Government’s enumerated

powers,” Defendants have “undermine[d] the sovereign interests of States.” Bond v. United States,

564 U.S. 211, 225 (2011).

236. Finally, to the extent Defendants’ actions are deemed to fall within the scope of 10

U.S.C. § 12406, then such use of Section 12406 constitutes an as-applied violation of the Tenth

Amendment insofar as it restricts the State’s ability to exercise its reserved police power over its

citizens, including through an impermissible coercive choice.

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Fourth Claim for Relief

Violation of Equal Sovereignty Under the U.S. Constitution
Against All Defendants

237. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

238. “Not only do States retain sovereignty under the Constitution, there is also a

‘fundamental principle of equal sovereignty’ among States.” Shelby Cnty., Ala. v. Holder, 570

U.S. 529 U.S. 529, 544 (2013) (citation omitted). The Supreme Court has long recognized that

our nation “was and is a nation of States, equal in power, dignity, and authority,” and that this

“constitutional equality of the States is essential to the harmonious operation of the scheme upon

which the Republic was organized.” Coyle v. Smith, 221 U.S. 559, 567, 580 (1911).

239. This “fundamental principle of equal sovereignty remains highly pertinent in

assessing subsequent disparate treatment of States” by the federal government. Shelby Cnty, 570

U.S. at 544 (citation omitted).

240. Defendants have trampled these principles by selecting certain politically

disfavored jurisdictions – including Chicago and Illinois – for an involuntary deployment of

military troops under federal control. “And despite the tradition of equal sovereignty,” Defendants

have applied this harsh infringement on state sovereignty “to only [three] states” and the District

of Columbia. Id. at 544.

241. Such an “extraordinary departure from the traditional course of relations between

the States and the Federal Government” can only be justified by dire and “unique circumstances,”

and must be limited to “areas where immediate action” is truly necessary. Id. at 546.

242. Defendants have treated the States differently, subjecting only some States to

involuntary National Guard deployment without satisfying that high bar. On the contrary,

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defendants have failed to provide even a reasonable explanation for the differential treatment.

Instead, Defendants have treated certain States differently based solely on whether the

administration approves of the State and local policies within those States. Illinois, Oregon,

California, and the District of Columbia, all states and cities disfavored by Defendants, have been

the subject of involuntary federalization of National Guard troops. Defendants have not deployed

state National Guards in any other state without their consent. Such disparate treatment without

any basis violates the principle of equal sovereignty. Defendants’ selection of Illinois for National

Guard federalization and deployment is, at best, arbitrary and, at worst, a politically motivated

retaliation for Plaintiffs’ adoption of policies that the President disfavors, and it harms the state of

Illinois.

Fifth Claim for Relief

Violation of the Administrative Procedure Act § 706(2)(A) - Arbitrary and Capricious
Against Agency Defendants

243. Plaintiffs reallege and incorporate the foregoing allegations as if fully set forth

herein.

244. Under the Administrative Procedure Act, a court must “hold unlawful and set aside

agency action” that is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance

with the law,” or that is “contrary to constitutional right [or] power,” 5 U.S.C. § 706(2)(A)-(B).

245. Defendants United States Department of Homeland Security, United States

Department of Defense, United States Army are each an “agency” under the APA, 5 U.S.C. §

551(1).

246. The DOD and Secretary Hegseth’s Federalization Order, federalizing up to 300

members of the Illinois National Guard at the request of DHS and Secretary Noem, and the Texas

Mobilization Order, federalizing up to 400 members of the Texas National Guard to deploy to

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Illinois and Oregon, each constitute final agency action because each represents the

“consummation” of the agency’s decision-making process and an action “from which legal

consequences will flow.” Bennett v. Spear, 520 U.S. 154, 178 (1997) (citation and quotation marks

omitted).

247. An agency action is arbitrary or capricious where it is not “reasonable and

reasonably explained.” FCC v. Prometheus Radio Project, 592 U.S. 414, 423 (2021). This requires

that an agency provide “a satisfactory explanation for its action[,] including a rational connection

between the facts found and the choice made.” Motor Vehicle Mfrs. Ass’n, Inc. v. State Farm Mut.

Auto. Ins. Co., 463 U.S. 29, 43 (1983) (internal quotation marks omitted). This “reasoned

explanation requirement of administrative law . . . is meant to ensure that agencies offer genuine

justifications for important decisions, reasons that can be scrutinized by courts and the interested

public.” Dep’t of Commerce v. New York, 588 U.S. 752, 785 (2019).

248. Agencies may not rely on explanations that are “incongruent with what the record

reveals about the agency’s priorities and decisionmaking process.” Id. A court “may uphold agency

action only on the grounds that the agency invoked when it took the action.” Michigan v. EPA,

576 U.S. 743, 758 (2015) (citing SEC v. Chenery Corp., 318 U.S. 80, 87 (1943)).

249. Defendants DHS, DOD, and Army have provided no reasoned basis or explanation

for these final agency actions. On the contrary, for the reasons described herein, the

implementation by DHS, DOD, and Army of the Federalization Order, and/or the Texas

Mobilization Order is arbitrary and capricious because, as discussed above, each relies on false

statements and is pretextual.

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250. Finally, the Federalization Order and the Texas Mobilization Order are further

arbitrary and capricious because each is in excess of constitutional and statutory authority,

including the limitations in 10 U.S.C. § 12406 and the Posse Comitatus Act.

Sixth Claim for Relief

Violation of the Administrative Procedure Act 5 U.S.C. § 706(2)(A)-(C) - Action in Excess
of Statutory and Regulatory Authority, Not in Accordance with Law, and Contrary to
Law
Against Agency Defendants

251. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

252. Under the Administrative Procedure Act, a court must “hold unlawful and set aside

agency action” that is “not in accordance with the law,” that is “contrary to constitutional right [or]

power,” or that is “in excess of statutory jurisdiction, authority, or limitations, or short of statutory

right.” 5 U.S.C. § 706(2)(A)-(C).

253. Defendants United States Department of Homeland Security, United States

Department of Defense, and the United States Army are each an “agency” under the APA, 5 U.S.C.

§ 551(1).

254. Congress enacted the APA “as a check upon administrators whose zeal might

otherwise have carried them to excesses not contemplated in legislation creating their offices.”

Loper Bright Enters. v. Raimondo, 603 U.S. 369, 391 (2024) (quoting U.S. v. Morton Salt, 338

U.S. 632, 644 (1950)). In Loper Bright, the Supreme Court clarified that historical principles of

“respect” did not equate to deference, and that “Section 706 makes clear that agency interpretations

of statutes—like agency interpretations of the Constitution—are not entitled to deference.” Id. at

392. Rather, it “remains the responsibility of the court to decide whether the law means what the

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agency says.” Id. (quoting Perez v. Mortg. Bankers Ass’n, 575 U.S. 92, 109 (Scalia, J., concurring

in judgment)).

255. The DOD and Secretary Hegseth’s Federalization Order, federalizing up to 300

members of the Illinois National Guard at the request of DHS and Secretary Noem, and the Texas

Mobilization Order constitute final agency action because each represents the “consummation” of

the agency’s decision-making process and because it represents action “from which legal

consequences will flow.” Bennett v. Spear, 520 U.S. 154, 178 (1997) (citation and quotation marks

omitted).

256. For the reasons discussed above, the Federalization Order is contrary to and exceeds

authority in numerous laws and regulations, including 10 U.S.C. § 12406, the Posse Comitatus

Act, and 10 U.S.C. § 275.

257. The DOD and Secretary Hegseth’s Texas Mobilization Order, federalizing up to

400 members of the Texas National Guard at the request of DHS and Secretary Noem also

constitutes final agency action because it represents the “consummation” of the agency’s decision-

making process and because it represents action “from which legal consequences will flow.”

Bennett, 520 U.S. at 178 (citation and quotation marks omitted).

258. For the reasons discussed above, the Texas Mobilization Order is contrary to and

exceeds authority in numerous laws and regulations, including 10 U.S.C. § 12406, the Posse

Comitatus Act, and 10 U.S.C. § 275.

259. And, for the reasons described herein, the implementation by defendants

Department of Defense, Department of Homeland Security, and the U.S. Army of the

Federalization Order and the Texas Mobilization Order is contrary to and in excess of authority

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and limitations in 10 U.S.C. § 12406, the Posse Comitatus Act, and 10 U.S.C. § 275, as well as

their implementing regulations.

Seventh Claim for Relief

Violation of the U.S. Constitution Separation of Powers
Against All Defendants

260. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

261. The Constitution’s separation of powers doctrine and the Take Care Clause all place

limitations on the exercise of executive authority.

262. The separation of powers doctrine is “foundational” and “evident from the

Constitution’s vesting of certain powers in certain bodies.” Seila Law LLC v. CFPB, 591 U.S. 197,

227 (2020); see also Trump v. United States, 603 U.S. 593, 637-38 (2024).

263. The Constitution grants Congress the power to regulate the domestic activities of

state militias and to authorize the President to “provide for calling forth the Militia to execute the

Laws of the Union, suppress Insurrections and repel Invasions.” U.S. Const. art. I, § 8, cl. 15. The

Constitution limits the President’s authority to act as Commander-in-Chief of the “Militia of the

several States” to instances when they are “called into the actual Service of the United States.”

U.S. Const. art. II, § 2, cl. 1.

264. The Executive’s powers are limited to those specifically conferred by “an act of

Congress or from the Constitution itself.” Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579,

585 (1952). The Executive has no power “to enact, to amend, or to repeal statutes.” Clinton v. City

of New York, 524 U.S. 417, 438 (1998).

265. Defendants have violated the Separation of Powers doctrine by asserting authority

over Illinois’s state Militia that the Constitution and federal law expressly assign to Illinois.

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266. Additionally, defendants have violated the Separation of Powers doctrine by

disregarding the limits in the Posse Comitatus Act and 10 U.S.C. § 275 barring the participation

of federal military forces in law enforcement.

267. This court is authorized to enjoin any action by the Executive and his agencies that

“is unauthorized by statute, exceeds the scope of constitutional authority, or is pursuant to

unconstitutional enactment.” Youngstown Sheet & Tube Co. v. Sawyer, 103 F. Supp. 569, 576

(D.D.C. 1952), aff’d, 343 U.S. 579 (1952).

Eighth Claim for Relief

Violation of the U.S. Constitution Militia Clauses
Against All Defendants

268. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

269. The Militia Clauses expressly provide that “Congress shall have Power … To

provide for calling forth the Militia to execute the Laws of the Union, suppress Insurrections and

repel Invasions….” U.S. Const. art. I, § 8, cl. 15. They further provide that Congress has authority

“To provide for organizing, arming, and disciplining the Militia, and for governing such Part of

them as may be employed in the Service of the United States, reserving to the States respectively,

the Appointment of Officers, and the Authority of training the Militia according to the discipline

prescribed by Congress…” U.S. Const. art. I, § 8, cl. 16.

270. Defendants have violated each of the Milita Clauses by asserting authority over

Illinois’s state Militia that the Constitution and federal law expressly assigns to Illinois

Additionally, Defendants have violated each of the Militia Clauses by disregarding the limits in

the Posse Comitatus Act and 10 U.S.C. § 275 barring the participation of federal military forces in

law enforcement.

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271. This court is authorized to enjoin any action by the Executive and his agencies that

“is unauthorized by statute, exceeds the scope of constitutional authority, or is pursuant to

unconstitutional enactment.” Youngstown, 103 F. Supp. at 576.

Ninth Claim for Relief

Violation of the U.S. Constitution Take Care Clause
Against All Defendants

272. Plaintiffs reallege and incorporate by reference the allegations set forth in each of

the preceding paragraphs of this Complaint.

273. The Take Care Clause provides that the Executive must “take Care that the Laws

be faithfully executed . . . .” U.S. Const. art. II, § 3; Util. Air Regul. Grp. v. EPA, 573 U.S. 302,

327 (2014) (“Under our system of government, Congress makes laws and the President . . .

faithfully executes them.”) (internal quotation marks and citation omitted).

274. The Executive violates the Take Care Clause where it overrides statutes enacted by

Congress and signed into law or duly promulgated regulations implementing such statutes. See In

re United Mine Workers of Am. Int’l Union, 190 F.3d 545, 551 (D.C. Cir. 1999) (holding that “the

President is without authority to set aside congressional legislation by executive order”); Kendall

v. United States, 37 U.S. (12 Pet.) 524, 613 (1838) (rejecting argument that by charging the

President with faithful execution of the laws, the Take Care clause “implies a power to forbid their

execution”).

275. Defendants have violated the Take Care Clause doctrine by asserting authority over

Illinois’s state Militia that the Constitution and federal law expressly assigns to Illinois.

Additionally, Defendants have violated the Take Care Clause doctrine by and disregarding the

limits in the Posse Comitatus Act and 10 U.S.C. § 275 barring the participation of federal military

forces in law enforcement.

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276. This court is authorized to enjoin any action by the Executive and his agencies that

“is unauthorized by statute, exceeds the scope of constitutional authority, or is pursuant to

unconstitutional enactment.” Youngstown, 103 F. Supp. at 576.

Prayer for Relief

Wherefore, Plaintiffs request that the Court enter judgment against Defendants and award

the following relief:

A. Declare that Defendants’ federalization and deployment of the National Guard of the
United States, any state National Guard, or deployment of the U.S. military in Illinois,
including under 10 U.S.C. § 12406, is unconstitutional and/or unlawful because it:
(a) is ultra vires; (b) violates the APA; and (c) is contrary to the Constitution of the
United States;

B. Hold unlawful and enjoin Defendants’ federalization and deployment of the National
Guard of the United States, any state National Guard, or deployment of the U.S.
military, pursuant to the Federalization Order, the Texas Mobilization Order, and any
similar order effectuating the mobilization of the National Guard of the United States,
any state National Guard, or deployment of the U.S. military in Illinois over the
objection of the Governor of Illinois;

C. Permanently and preliminarily enjoin defendant Hegseth and the Department of

Defense from federalizing or otherwise deploying forces in implementation of the
Federalization Order, the Texas Mobilization Order, and any similar order effectuating
the mobilization of the National Guard of the United States, any state National Guard,
or deployment of the U.S. military in Illinois over the objection of the Governor of
Illinois;

D. Pursuant to 5 U.S.C. § 706 and 28 U.S.C. § 2202, vacate and set aside the
Federalization Order, the Texas Mobilization Order, and any similar order effectuating
the mobilization of the National Guard of the United States, any state National Guard,
or deployment of the U.S. military in Illinois over the objection of the Governor of
Illinois;

E. Award the Plaintiffs their costs and reasonable attorneys’ fees; and

F. Award such additional relief as the interests of justice may require.

Dated this 6th Day of October, 2025

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KWAME RAOUL
Attorney General of Illinois

by:

/s/ Sarah J. North .

CARA HENDRICKSON
Executive Deputy Attorney General
CHRISTOPHER WELLS
Division Chief, Public Interest Division
SARAH J. NORTH
Deputy Division Chief, Public Interest
Division
SARAH HUNGER
Deputy Solicitor General
KATHARINE ROLLER
Complex Litigation Counsel
GRETCHEN HELFRICH
Deputy Chief, Special Litigation Burean
KATHERINE PANNELLA
Senior Assistant Attorney General
SHERIEF GABER
MICHAEL TRESNOWSKI
Assistant Attorneys General
Office of the Illinois Attorney General
115 South LaSalle Street
31st Floor
Chicago, Illinois 60603
(312) 814-3000
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]

Counsel for the State of Illinois

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MARY B. RICHARDSON-LOWRY
Corporation Counsel of the City of Chicago

By: /s/ Stephen J. Kane

Stephen J. Kane
Chelsey B. Metcalf
City of Chicago Department of Law
121 North LaSalle Street, Room 600
Chicago, Illinois 60602
312-744-6934
[email protected]
[email protected]

Counsel for the City of Chicago

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