Howell Bans Todd Lyons Memo in Washington Dc Immigration Arrests Ruling
Judge Beryl A. Howell tightened the washington dc immigration arrests ruling today, ordering the Trump administration not to rely on a Todd Lyons memorandum when making warrantless civil immigration arrests in the District. Her order enforces an earlier injunction that barred arrests without a warrant and without individualized probable cause that a person was likely to escape before a warrant could be obtained.
The ruling follows a motion the plaintiffs filed in February after they said federal agents had made several dozen arrests without trying to establish escape risk or by using perfunctory reasoning. The case began in September, when four local residents and We Are CASA filed a class action after agents spent weeks arresting people they perceived to be Latino throughout Washington, D.C.
Howell and the Todd Lyons memo
Howell granted the plaintiffs’ motion and barred defendants from relying on the probable cause standard or analytical approach set out in the five-page memorandum issued in January by former Acting Director of Immigration and Customs Enforcement Todd Lyons. The plaintiffs said that memo misread the escape-risk standard the court had already required agents to use before arresting people without a warrant.
The court’s earlier preliminary injunction, issued in December 2025, required the Trump administration to stop warrantless civil immigration arrests in D.C. unless officers made individualized probable cause determinations that the person was likely to escape before a warrant could be obtained. That earlier order is now the standard Howell said the administration had to follow.
February motion in court
In their February filing, the plaintiffs asked the court to enforce the injunction after presenting evidence of several dozen arrests, saying agents made no effort to obtain probable cause or relied on cursory explanations to justify arrests without a warrant. Aditi Shah, a staff attorney with the American Civil Liberties Union of the District of Columbia, said the court recognized that the Trump administration violated the preliminary injunction order and that the new order reaffirms the administration is not above the law.
Shah also said the legal team would continue to defend the rights of people who live in, work in, and visit D.C., including immigrants. The plaintiffs are represented by the American Civil Liberties Union of the District of Columbia, the American Civil Liberties Union, the Amica Center for Immigrant Rights, We Are CASA, the National Immigration Project, the Washington Lawyers’ Committee for Civil Rights and Urban Affairs, and Covington & Burling.
We Are CASA in D.C.
Madeleine Gates, associate counsel at the Washington Lawyers’ Committee for Civil Rights and Urban Affairs, said immigration agents continue to skip crucial safeguards before arresting D.C. residents for immigration violations. Shana Khader, deputy legal director for We Are CASA, said the warrantless arrests have terrorized communities and created fear and instability for families across D.C.
Khader said parents are afraid to go to work, children worry their loved ones may not come home, and entire communities are forced to live with uncertainty. The court’s latest order leaves agents in D.C. under the same requirement Howell imposed in December 2025: they cannot make warrantless civil immigration arrests unless they make an individualized probable cause determination about escape risk first.
