Judge's Conclusions About Risks of Identification for ICE Officers

Judge's Conclusions About Risks of Identification for ICE Officers Eugene Volokh | 7.3.2026 9:02 PM From U.S. v. Virginia, decided yesterday by Judge Robert Payne (E.D. Va.); these conclusions played a role in the court's "irreparable harm" analysis, one of the factors that the court had to consider in deciding whether to grant a preliminary injunction: The record in this case shows that, with increased enforcement activity and the resistance thereto, there came to be "increasingly common threats of targeted harassment of and retaliation against federal immigration officers for simply doing their jobs." In particular, it is shown by the affidavit of Eric S.

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