A federal appeals court delivered a sharp rebuke to an Obama-appointed judge last week, overturning a sweeping ruling that had placed major restrictions on federal immigration enforcement operations in Chicago.
At the center of the dispute was U.S. District Judge Sara Ellis, who was nominated to the federal bench in 2013 by former President Barack Obama. In October, Ellis issued a broad preliminary injunction targeting the Department of Homeland Security’s enforcement tactics during Operation Midway Blitz, a Trump administration initiative aimed at cracking down on illegal immigration and related crime in the Chicago area.
Her order imposed extensive limits on how federal agents could respond to demonstrations or confrontations tied to immigration enforcement activity. The injunction barred agents from using various crowd-control tactics and even restricted them from issuing dispersal orders in some circumstances.
According to the appellate ruling, Ellis’ order amounted to “a sweeping preliminary injunction regulating all federal immigration enforcement efforts districtwide.”
The ruling also required Gary Bovino, who at the time oversaw DHS operations in Chicago, to appear before Ellis daily to report on the agency’s compliance with her directives.
Ellis later issued a lengthy 233-page opinion defending her decision. The opinion reportedly opened with a literary reference to Chicago poet Carl Sandburg before launching into a detailed critique of DHS operations and the tactics used by federal agents.
The Seventh Circuit just delivered a haymaker to Obama-appointee Judge Sara Ellis for her efforts to limit federal enforcement of immigration laws. It accused her of “effectively establish[ing]” herself “as the supervisor of all Executive Branch activity in the city of Chicago.”
— Jonathan Turley (@JonathanTurley) March 8, 2026
Under her injunction, immigration authorities were prohibited from using several forms of physical force — including shoving, tackling, or otherwise restraining individuals — unless there was an immediate threat of physical harm. The order also created special protections for individuals identifying themselves as journalists, allowing them to remain in areas even after dispersal orders were issued to the broader crowd.
The Trump administration quickly appealed the ruling, and the appellate court temporarily stayed the injunction while preparing to review the case.
But the legal battle took an unexpected turn in December. The plaintiffs — a group of protesters and journalists who claimed their First and Fourth Amendment rights had been violated — asked Ellis to dismiss the case. Their reasoning was that the clashes surrounding Operation Midway Blitz had largely subsided, making the dispute legally moot.
The Justice Department also supported dismissing the case, though for strategic legal reasons of its own.
Judge Ellis ultimately agreed to dismiss the case — but she did so “without prejudice,” meaning the lawsuit could be revived in the future. That detail became a central point of contention.
A three-judge panel from the U.S. Court of Appeals for the Seventh Circuit concluded that Ellis’ approach left the door open for the same sweeping injunction to be reinstated later. In a strongly worded opinion, the majority said the decision created the possibility that plaintiffs could simply refile the case and attempt to reimpose the same restrictions on federal enforcement.
“The practical upshot of the district court’s decision is that the named plaintiffs and members of the class can refile in federal court tomorrow and try to reimplement the injunction anew,” the ruling stated.
The appellate panel ultimately ruled against Ellis, effectively shutting down the possibility of the injunction being revived through the same legal pathway.
The decision came from a 2–1 split panel consisting of Chief Judge Michael Brennan and Judge Michael Scudder in the majority, with longtime conservative jurist Frank Easterbrook dissenting. Easterbrook argued that if both sides wanted the case dismissed, the court should have simply allowed that outcome.
However, the majority concluded that Ellis’ handling of the case raised significant constitutional concerns that warranted a definitive ruling rather than allowing the legal dispute to quietly disappear.
