Like thousands of Oregonians everywhere, on Friday morning, November 21, 2025, Petitioner M-E-G-G- was simply heading into work, when multiple vehicles swarmed her, forced her to pull over, and trapped her on the side of the road. This action was part of an ongoing and indiscriminate dragnet meant to achieve a quota of arrests, regardless of what the law requires the U.S. Department of Homeland Security (“DHS”) to do when taking away someone’s liberty. DHS had no basis to stop M-E-G-G-, had no warrant or probable cause to arrest her, and made no individualized custody determination before transferring her to an out-of-state detention center away from her community and legal representation. Even now, several days into her illegal executive detention, DHS has yet to propound any lawful basis for her detention.

But the U.S. Constitution could not speak more clearly: “No person shall be . . . deprived of life, liberty, or property, without due process of law”. U.S. Const. amend. V. Petitioner M-E-G-G-’s detention has been unlawful at every moment. Respondent DHS unlawfully stopped and detained her, without reasonable suspicion; unlawfully arrested her without a warrant and without probable cause or reason to believe she had committed an immigration violation, and that she would flee before a warrant could be obtained; and denied her a meaningful opportunity to be heard in violation of her constitutional right to due process and Respondents’ own regulations.