(MINNESOTA) โ U.S. District Judge Patrick Schiltz, Chief Judge for the District of Minnesota, sharply rebuked U.S. Attorney Daniel Rosen and ICE officials for repeated defiance of court orders in immigration cases, warning that the court could escalate beyond civil contempt if violations continue.
Schiltz framed the clash as a test of court authority and due process in immigration matters, arguing the issue reflected persistent noncompliance rather than a one-off mistake and that detainees and litigants bear the consequences when orders are ignored.
In a February 2026 letter that followed a January rebuke, Schiltz described a court increasingly reliant on coercive remedies to secure compliance, setting up a direct confrontation with the federal lawyers and agency officials responsible for carrying out judicial directives.
That earlier January rebuke accused the Trump administration of defying over 90 court orders that month, and the February letter treated the pattern as ongoing, not resolved by the courtโs warning. Schiltz tied the issue to immigration enforcement operations that can generate rapid litigation and urgent court deadlines.
โโIncreasingly, this court has had to resort to using the threat of civil contempt to force ICE to comply with orders,โ Schiltz wrote. โThis court is not aware of another occasion in the history of the United States in which a federal court has had to threaten contempt โ again and again and again โ to force the United States government to comply with court orders.โ
Schiltz added that the court would keep escalating pressure if needed, including a shift from civil contempt to criminal contempt as the court described it. โThis court will continue to do whatever is required to protect the rule of law, including, if necessary, moving to the use of criminal contempt,โ he wrote. โOne way or another, ICE will comply with this court’s orders.โ
Rosen pushed back after the January warning, and Schiltz treated that response as part of the dispute over how to characterize the governmentโs conduct. Schiltz criticized Rosenโs February 9 email response, which called Schiltzโs initial rebuke โfar beyond the pale of accuracyโ and claimed his civil division lawyers โdidn’t deserve it.โ
The judge responded with language that sharpened the personal and institutional friction while keeping his focus on compliance failures by ICE. โIf anything is ‘beyond the pale,’ it is ICE’s continued violation of the orders of this Court,โ Schiltz wrote.
Schiltz also singled out the pressures placed on line attorneys, praising lawyers such as former civil chief Ana Voss while faulting leadership decisions that, in his telling, made court compliance harder. He said they were placed in an โimpossible positionโ by Rosen and DOJ superiors amid 3,000 ICE agents deployed to Minnesota without provisions for ensuing lawsuits.
Beyond the rhetoric, Schiltz reported a verified expansion in the scope of violations after the courtโs earlier warning, describing misconduct that continued even as the court was already threatening sanctions. He verified an additional 113 violations of court orders in 77 more cases after his January letter, most post-dating it.
The volume and timing mattered to Schiltzโs argument because repeated, post-warning violations can strengthen the case for tighter court supervision and harsher remedies, including sanctions designed to compel performance rather than compensate for past harm. Schiltzโs letter treated the accumulating tally as evidence that warnings alone had not changed behavior.
Other judges in Minnesota took parallel steps that reflected similar concerns about ICE noncompliance and the strains it creates for courts managing urgent detention and removal disputes. Judge Eric Tostrud held officials in civil contempt, ordering payment for a detainee’s plane ticket transferred to Texas against his order.
Judge Jeffrey Bryan, in a separate set of disputes, scheduled a March 2026 contempt hearing for two dozen cases involving ICE withholding released detainees’ property, widening the compliance fight to include property and release logistics across multiple matters. Bryanโs order summoned Rosen to court on the same day as Schiltzโs rebuke.
Schiltzโs letter and the related contempt actions underscored how enforcement deployments can collide with court-ordered process when internal coordination breaks down, leaving attorneys and agencies scrambling to meet judicial commands in fast-moving cases. The judgeโs language also signaled that courts can turn from repeated warnings to escalating measures when they conclude violations persist despite earlier admonitions.
The broader impatience extended beyond Minnesota, with a New Jersey judge using stark language to describe what he saw as a wider problem. โโIt ends today,’ wrote Zahid Quraishi, a federal judge in New Jersey who described rampant ‘misconduct’ by the administration.โ
U.S. District Judge Patrick Schiltz Holds U.S. Attorney Daniel Rosen in Civil Contempt
Chief Judge Patrick Schiltz has warned federal officials that continued defiance of court orders in immigration cases will lead to criminal contempt charges. Following over 200 recorded violations, including 113 after an initial warning, the court is challenging the government’s persistent noncompliance. The dispute highlights a growing rift between the judiciary and immigration enforcement leadership regarding the administration of justice and legal accountability.