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

 March 10, 2026

A three-judge panel of the U.S. Court of Appeals for the Seventh Circuit tossed out a class-wide preliminary injunction that had attempted to restrain Homeland Security and Justice Department authorities from carrying out immigration enforcement in Chicago.

Fox News reported that the 2-1 decision didn't just reverse the lower court. It rebuked the entire premise of what Judge Sara Ellis, an Obama appointee, had tried to do.

The panel, composed of two Trump appointees and a Reagan appointee, found that Ellis' injunction was "overbroad" and "constitutionally suspect."

The court dismissed the appeal outright, calling it the "best way to wipe the slate clean" in what it termed an "extraordinary case."

Attorney General Pam Bondi called it a "huge legal win."

What Ellis Tried to Do

Ellis had issued a sprawling injunction against federal immigration enforcement in Chicago, targeting operations connected to Operation Midway Blitz, a program launched last year by the Trump administration to crack down on illegal immigration and street crime in the city.

The operation had generated a string of clashes between protesters and agents, and plaintiffs including groups of protesters and journalists brought suit.

Ellis responded with a 233-page opinion explaining why she granted the injunction. She insisted it "was not novel" and ordered agents to follow "current DHS policies regarding use of force and body-worn cameras." In her telling, nothing about it broke new ground:

"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 Seventh Circuit saw it very differently.

The Appellate Court's Rebuke

The panel's language was unusually pointed. It found that Ellis' order had "effectively established the district court as the supervisor of all Executive Branch activity in the city of Chicago."

The injunction applied to "the entire Departments of Homeland Security and Justice, as well as anyone acting in concert with them."

Read that again. A single district judge in Chicago attempted to assert supervisory authority over the entirety of two Cabinet-level departments and anyone working alongside them. Not for a specific operation. Not for a specific set of agents. All of them. Everywhere in Chicago.

The appeals court had previously paused the injunction, noting at the time that its "practical effect" was "to enjoin all law enforcement officers within the Executive Branch." But the full ruling went further, finding that Ellis "likely abused its discretion by issuing such a sweeping injunction."

The panel zeroed in on the injunction's demand that federal agents comply with "all current and future internal guidance, policies, and directives," calling out the obvious constitutional problem: "federal courts do not exercise general oversight of the Executive Branch."

The court also noted that requiring compliance with existing policy was a hollow exercise, "spawning any legal consequences" for conduct that internal policy already governed.

The lone dissenter was Judge Frank Easterbrook, the Reagan appointee on the panel, who argued that only the appeal should have been dismissed since both sides had asked for that. Even the dissent didn't defend the substance of Ellis' order.

The Reaction

Jonathan Turley, a George Washington University law professor, said the appellate court "delivered a haymaker."

Bondi's statement framed the decision as part of a larger enforcement picture:

"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."

Former longtime federal prosecutor Bill Shipley distilled the panel's message to Ellis in a post on X: "You don't get to run DHS and DOJ."

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

The Bigger Pattern

Bier's framing is worth examining because it reveals a particular theory of judicial power that has become fashionable on the left: that when a single district judge believes the executive branch is misbehaving, the appropriate remedy is effectively unlimited injunctive authority over entire departments of the federal government.

This is not how separation of powers works. It is not how it has ever worked. The Seventh Circuit's ruling makes that clear in terms that should be difficult to misunderstand. Federal courts do not sit as roving supervisors of the executive branch, no matter how strongly a judge feels about a particular enforcement operation.

The Chicago case fits a pattern that has played out in courtrooms across the country. District judges, often appointed by Democratic presidents, issue maximalist injunctions that reach far beyond the specific plaintiffs or conduct before them. The injunctions function as policy vetoes dressed in judicial language. And when appellate courts review them, the overreach becomes obvious.

Ellis wrote 233 pages to justify her order. The Seventh Circuit needed far fewer words to explain why it failed. The length of a judicial opinion is not a measure of its soundness. Sometimes it's a measure of how much work is required to make an unsound position look reasonable.

What Comes Next

Operation Midway Blitz has largely ended, but the legal principle established here outlasts any single operation. The Seventh Circuit has drawn a clear line: district courts cannot convert enforcement disputes into open-ended supervisory mandates over federal agencies.

Plaintiffs who believe their rights were violated in specific incidents retain the ability to bring specific claims. What they cannot do is recruit a sympathetic judge to run immigration enforcement for an entire city.

Chicago's elected officials have spent years resisting federal immigration enforcement. Now the judicial backstop they relied on has been knocked out.

The executive branch enforces the law. Courts adjudicate specific disputes. One Obama-appointed judge in Chicago does not get to manage two federal departments from the bench.

The Seventh Circuit just reminded everyone how this is supposed to work.


About Maria Reese Paul

Maria is a staff writer covering conservative politics, policy, and culture with a focus on Washington’s most pressing debates for Heritage Review. She is Passionate about amplifying voices often overlooked in mainstream media.

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