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Federal Judge Finds Probable Cause to Hold Trump Administration in Criminal Contempt Over Deportation of Venezuelan Migrants

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In a sharply worded ruling, U.S. District Judge James E. Boasberg found probable cause to hold the Trump administration in criminal contempt for violating a federal court order that temporarily blocked the deportation of a class of Venezuelan migrants targeted under the Alien Enemies Act, a centuries-old law invoked by President Donald Trump to remove alleged gang members.

The ruling stems from the case of J.G.G., et al., v. Donald J. Trump, et al., filed in the U.S. District Court for the District of Columbia. On March 15, 2025, Judge Boasberg issued a written Temporary Restraining Order (TRO) barring the government from transferring noncitizens in U.S. custody, subject to removal solely under a Presidential Proclamation, to foreign custody. The TRO aimed to halt deportations pending judicial review, as required by federal due-process protections.

However, according to the official court memorandum released this week, the Trump administration defied the order, completing the deportation of two planeloads of migrants to El Salvador in the early hours of March 16—hours after the court’s ruling.

“These individuals were spirited out of the United States by the Government before they could vindicate their due-process rights,” Boasberg wrote in the 46-page memorandum. “Rather than comply with the Court’s Order, the Government continued the hurried removal operation.”

The deported migrants were transferred to CECOT, a high-security prison in El Salvador known for detaining suspected gang members. Court filings indicate that plaintiffs denied affiliations with the targeted gang, Tren de Aragua, and the Supreme Court later affirmed that due-process protections require notice and an opportunity to challenge removability before deportation.

Boasberg criticized the administration’s “increasing obstructionism,” noting that it refused to provide basic flight details, citing national security concerns, even after publicly sharing operational details via social media posts. The court highlighted a retweet by the Secretary of State of a mocking post by El Salvador’s President, which suggested defiance of the court’s order. Despite multiple opportunities to explain or correct its conduct, the administration’s responses were “unsatisfactory,” leading Boasberg to conclude that its actions showed “willful disregard” for judicial authority, meeting the threshold for probable cause of criminal contempt.

The administration argued that the flights had already departed U.S. airspace before the TRO was issued and that the order did not explicitly require the return of planes in transit. The court rejected this reasoning, finding the TRO’s directive clear given its context and urgency.

The Supreme Court later vacated the TRO on jurisdictional grounds (Trump v. J.G.G., 2025 WL 1024097), holding that such challenges must be filed via habeas corpus in the district of confinement. However, Boasberg emphasized that compliance with court orders is required until they are lawfully overturned.

The court has given the administration until April 23, 2025, to either reassert custody of the deported individuals to allow habeas challenges or identify the officials responsible for authorizing the flights. Failure to comply could trigger formal contempt proceedings and potential criminal referrals.

This case underscores ongoing tensions between the judiciary and the Trump administration’s strict immigration enforcement policies, which have sparked widespread legal and political debates.

Source: U.S. District Court for the District of Columbia, Case 1:25-cv-00766-JEB, Document 81, April 16, 2025,

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