Restraining Order Limits Federal Agents' Force Against Protesters and Press

On October 9, 2025, U.S. District Judge Sara L. Ellis issued a sweeping Temporary Restraining Order (TRO) in the case of Chicago Headline Club v. Noem, significantly limiting the use of force by federal agents against peaceful protesters, journalists, and clergy in the Northern District of Illinois.

The TRO was granted in response to a lawsuit alleging that federal agents had used excessive and illegal force, including "near-lethal weapons," to suppress constitutionally protected activity during protests, particularly outside a U.S. Immigration and Customs Enforcement (ICE) facility in Broadview, Illinois.

Prohibited "Riot Control Weapons" and Tactics

The order explicitly prohibits federal agents from utilizing physical force, riot control weapons, or otherwise harmful and undue dispersal techniques against individuals they know or reasonably should know are journalists, protesters, or religious practitioners who are not posing an immediate threat to the safety of a law enforcement officer or others.

While the court's official order may contain specific legal definitions, the prohibited actions and weapons, as addressed in the case context and media reports, include:

• Kinetic Impact Projectiles (KIPs) (e.g., rubber bullets, pepper-balls)
• Tear Gas (CS/CN)
• Pepper Spray (OC)
• 40 mm Munitions Launchers
• Body slamming/tackling (and other undue physical force)

The order also requires federal agents to display visible identification and bars arrests of nonviolent protesters without probable cause.

Judicial Justification and Initial Limit

In granting the TRO, Judge Ellis emphasized the constitutional importance of the rights being protected. Judge Ellis was quoted as saying on the importance of the ruling: "Individuals are allowed to protest, are allowed to speak — that is guaranteed by the First Amendment of our Constitution, and it is a bedrock right that upholds our democracy."

The TRO has an initial 14-day limit, after which the court is scheduled to hear arguments on whether to extend the order into a longer-lasting preliminary injunction.

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Sources

• Protecting protesters and the press from unconstitutional federal force in Illinois https://protectdemocracy.org/work/protecting-protesters-and-the-press-from-unconstitutional-federal-force-in-illinois/
• Federal Judge Sides With Journalists, Protesters in Chicago Over Violent Tactics of Trump's Federal Agents | Common Dreams https://www.commondreams.org/news/ice-chicago-riot-weapons
• Judge orders halt to DHS agents' targeting of journalists in Chicago - Daily Herald https://www.dailyherald.com/20251009/nation-and-world-politics/judge-orders-halt-to-dhs-agents-targeting-of-journalists-in-chicago/
• Federal Judge Issues Temporary Restraining Order, Reining in Federal Agents' Use of Violence, and Protecting First Amendment Rights of Protesters, Clergy, and Press https://www.loevy.com/big-wins/federal-judge-issues-temporary-restraining-order-reining-in-federal-agents-use-of-violence-and-protecting-first-amendment-rights-of-protesters-clergy-and-press/