Seventh Circuit guts Obama appointee's sweeping injunction against immigration enforcement in Chicago

By 
, March 10, 2026

A three-judge panel of the U.S. Court of Appeals for the 7th Circuit tossed out a class-wide preliminary injunction that had blocked federal immigration enforcement across the city of Chicago.

As Fox News reported, the 2-1 decision dismantled what the panel called an "overbroad" and "constitutionally suspect" order issued by Obama-appointed federal Judge Sara Ellis, which had targeted the Department of Homeland Security and the Department of Justice.

The appeals court didn't mince words. It found that Ellis had "likely abused its discretion by issuing such a sweeping injunction," one that bound not just specific agents or operations but, as the panel described it, "the entire Departments of Homeland Security and Justice, as well as anyone acting in concert with them."

Attorney General Pam Bondi called the ruling a "huge legal win."

What the lower court tried to do

The case originated from clashes between protesters and federal agents during Operation Midway Blitz, an immigration enforcement operation the Trump administration launched last year in Chicago. Groups of protesters and journalists brought suit, and Ellis responded with a class-wide preliminary injunction against federal authorities carrying out enforcement in the city.

Ellis defended her order in a lengthy 233-page opinion, arguing it merely required agents to follow existing DHS policies on use of force and body-worn cameras:

"In other words, the Court's order should break no new ground, and indeed it tracks similar orders entered in other crowd control cases across the country."

The 7th Circuit saw it very differently. The panel found that the injunction's scope reached "all current and future internal guidance, policies, and directives," effectively installing the district court as a permanent supervisor of executive branch operations in Chicago. The court was blunt in its assessment: the order had "effectively established the district court as the supervisor of all Executive Branch activity in the city of Chicago."

That's not what federal courts do. The panel reminded Ellis of a basic constitutional principle: "Federal courts do not exercise general oversight of the Executive Branch."

A warning ignored

This wasn't the first time the 7th Circuit flagged problems with Ellis's approach. The appeals court had previously paused the injunction, warning at that time about its "practical effect" being "to enjoin all law enforcement officers within the Executive Branch." Ellis pressed forward anyway with her 233-page justification.

The appeals court's solution was decisive. When plaintiffs moved to dismiss their own lawsuit, the majority went further than simply granting that request. It vacated the injunction entirely, calling dismissal with vacatur "the best way to wipe the slate clean" in what it labeled an "extraordinary case." The decision left no ambiguity and no residual authority for the lower court, with the panel noting the injunction had been dissolved without "spawning any legal consequences."

The lone dissenter was Judge Frank Easterbrook, the Reagan appointee on the panel, who argued on narrower procedural grounds that only the appeal should have been dismissed since both sides had asked for that.

The real stakes

What happened in Chicago is part of a pattern that should trouble anyone who believes the executive branch has the constitutional authority to enforce immigration law. A single district court judge attempted to transform a dispute over specific enforcement encounters into a broad judicial veto over federal operations across an entire city. The 7th Circuit recognized the maneuver for what it was.

George Washington University law professor Jonathan Turley said the appellate court "delivered a haymaker" to Ellis. Former longtime federal prosecutor Bill Shipley distilled it even further, writing on X that the panel's message to Ellis was plain: "You don't get to run DHS and DOJ."

Bondi made clear the administration views this as validation, not just of the legal arguments but of the broader enforcement posture:

"President Trump is trying to protect American citizens while local elected officials REFUSE to do so. [DOJ] attorneys were proud to argue this case."

"We will continue fighting and WINNING for the President's law-and-order agenda."

The libertarian objection and why it misses

Not everyone cheered. The Cato Institute's David Bier criticized the ruling on X, arguing Ellis "was one of the only judges who did anything about the series of escalating abuses from CBP." He claimed she had investigated and found "numerous instances of perjury, constitutional violations, and other crimes," dismissing the 7th Circuit's decision as an "unnecessary lecture" that amounted to telling Ellis to "stop it."

But Bier's complaint actually proves the appeals court's point. Even if individual enforcement incidents merit judicial scrutiny, the remedy cannot be a blanket injunction that conscripts two entire federal departments under a single judge's supervision. Courts adjudicate specific cases and controversies. They do not install themselves as shadow administrators of federal law enforcement policy. The 7th Circuit drew that line clearly.

Chicago's elected leaders have made their position on immigration enforcement well known. They have resisted cooperation with federal authorities at every turn. What Ellis attempted was the judicial extension of that same resistance: if city hall won't block ICE, maybe a courtroom can.

The 7th Circuit just said no.

" A free people [claim] their rights, as derived from the laws of nature."
Thomas Jefferson