In Illinois’ Motion for a Temporary Restraining Order against Trump’s invasion, they describe how, on September 27, Greg Bovino drive three Chevy Tahoe’s into the Broadview police facility, promising a “shitshow,” later that day. That led to increased targeting of protestors and even journalists.

Around 7:00 a.m. on Saturday, September 27, three Chevrolet Tahoe SUVs appeared in the Broadview Police Department’s parking lot without invitation. 91 Federal agents, including Agent Bovino of the CBP, emerged from the vehicles with a message for the Broadview police: prepare for “a shitshow.”92 Specifically, federal agents, including Agent Bovino, told the Broadview police to expect increased use of chemical munitions and increased ICE activity in Broadview.93

That afternoon and evening, September 27, Agent Bovino and his colleagues followed through on their warning. Groups of federal agents repeatedly chased people on foot through the streets of Broadview in ongoing vehicle traffic.94 Around dusk, Agent Bovino and a large team of fatigue-clad, tactically equipped, and masked federal agents escorted multiple federal vehicles out of the ICE detention facility. 95 And, again, federal agents fired pepper balls, rubber bullets, and teargas cannisters at protestors.96 Over the course of the protests on September 26 and 27 in Broadview, DHS reported making a total of eleven arrests of protestors, though only five of the individuals arrested have been criminally charged. 97

[snip]

The actions of federal officials since the September 26 DHS-to-DOD memorandum belie the notion that the protests in Broadview exceed law enforcement’s capacity to address them. See 10 U.S.C. § 12406 (referring to inability to execute federal law with the “regular forces”). When confronted with a protest of approximately 100 people on the evening of September 27 outside the Broadview ICE facility, federal agents dispersed the protestors and arrested eleven people, including a journalist, in the process.140 Far from being overwhelmed by this protest, a DHS spokesperson bragged on social media about the number of arrests its agents made in response.

If the September 27 protest in Broadview had truly threatened to render the federal government incapable of executing federal law, then presumably the federal officials in charge of the ICE facility in Broadview would have focused their energy, attention, and resources on securing it the following day, September 28. Instead, CBP sent dozens of armed, fatigue-clad Border Patrol agents led by Agent Bovino through downtown Chicago—twelve miles removed from the ICE facility in Broadview.143 These actions are impossible to square with any good-faith argument from the federal government that it is unable to execute federal law in Broadview or anywhere else in Illinois.141 And although DHS declared all 200 people at the protest to be “rioters,” only eleven people had been arrested by federal agents, and, as of September 29, only five had been criminally charged by federal prosecutors.142

91 Id. [declaration of Broadview Police Chief Thomas Mills] ¶ 38.

92 Id.

93 Id.

94 “Agents chase after protesters, smoke and pepper bullets deployed outside Broadview ICE facility” ABC 7 Chicago (Sept. 26, 2025), available at https://www.youtube.com/watch?v=Byews1aX7XI.

95 “Protest continues outside ICE facility in Broadview,” CBS News (Sept. 27, 2025), available at https://www.cbsnews.com/chicago/video/protest-continues-outside-ice-facility-in-broadview/; see also Ex. 13, Declaration of Gil Kerlikowske (“Kerlikowske Decl.”), ¶¶ 46-51; Ex 15, Declaration of Commander Jacqueline Cepeda (Cepeda Decl.) at ¶ 8.

96 Ex. 4 (Mills Decl.) ¶¶ 35-36, 40.

97 Sabrina Franza, “Arrested Broadview ICE protestors appear in court; 2 held, 3 released,” CBS News Chicago (Sept. 29, 2025), available at: https://www.cbsnews.com/chicago/news/broadview-ice-facility-protesters-arrestcourt/.

[snip]

140 Ashlyn Wright, et al., “U.S. Border Patrol takes over security of Broadview ICE facility, protests continue over the weekend,” WGN (Sept. 27, 2025), available at: https://wgntv.com/news/operation-midway-blitz/protesters-rallyoutside-broadview-ice-facility-against-operation-midway-blitz/ (noting that “[a]bout 100 demonstrators” gathered outside the Broadview ICE facility” on Saturday, September 27); Cindy Hernandez, et al., “Broadview officials say ICE agents warned that mayor’s comments would bring consequences,” Chicago Sun-Times (Sept. 27, 2025), available at: https://chicago.suntimes.com/news/2025/09/27/ice-broadview-action-mayor-katrina-thompsonimmigration; @DHSgov, 8:50 a.m., Sept. 28, 2025 post on X.com, available at: https://x.com/DHSgov/status/1972297960319832252.

141 @DHSgov, 8:50 a.m., Sept. 28, 2025 post on X.com, available at: https://x.com/DHSgov/status/1972297960319832252.

142 ABC7 Chicago Digital Team, “Neurodivergent man among 5 protesters charged after clash at Broadview ICE facility, supporters say,” ABC7 (Sept. 29, 2025), available at: https://abc7chicago.com/post/ice-chicago-todayprotesters-expected-return-broadview-facility-weekend-clashes/17902425/. [my emphasis]

In the later discussion of the provocation, the filing noted that DHS called the eleven people arrested “violent rioters” in included two weapons that, DHS claimed, “were taken off rioters” at Broadview.

Two whole days ago, filing cited this story (at footnote 97), which noted that only five of the eleven claimed arrests were charged on the docket. The later section, as well as this story (at footnote 142), which noted that of those five, one was neurodivergent.

One of the people not formally challenged, as reflected in the lawsuit by Chicago’s civil society filed same day as Illinois’ lawsuit, journalist Stephen Held described being arrested at the “shitshow.”

The five cases that had been (and have been) filed by that point were:

• Paul Ivery, the neurodivergent man, who tragically spoke to the cops and admitted he said, “I’ll fucking kill you right now,” to a senior Border Patrol official who admitted he “does not specifically recall what IVERY said to [him] given the commotion.” The government initially asked for him to be detained, but then agreed to his release.
• Dana Briggs, whose hand a Border Patrol official grabbed to prevent him from handing his phone to a friend, after which (the complaint claims) Briggs hit the CBP officer in the wrist. The government agreed to his release on $10,000 unsecured bail.
• Ray Collins and Jocelyne Robledo, a couple who were pushed as the Feds tried to extend a perimeter of the facility. In the process, the Feds found (and put in their social media post) that each had weapons. Collins, who allegedly pushed back, was detained. He filed for release, noting that the weapons he and his partner both had were licensed Concealed Carry weapons. He was released on bail on October 2.
• Hubert Mazur. Even the complaint admits that the the alleged Border Patrol victim pushed Mazur first, which led both of them to fall to the ground. He was released on his how recognizance.

Yesterday, a day before his preliminary hearing, the government moved to dismiss the case against Mazur. the docket minute explains that when the government reviewed the video evidence of the incident, they decided they could not even charge a misdemeanor.

The government provided additional basis for its motion, noting that the government’s review, after defendant’s arrest, of additional body-worn camera video evidence caused the government to decide not to file an information in this case, in which the compliant charged the case as a misdemeanor. Further, the government confirmed on the record that prior to issuance of the complaint, the complaint affiant had sworn under oath that the affiant had reviewed video evidence that corroborated the complaint’s version of events. The Court confirmed at the hearing that such sworn affirmation was a substantial part of the basis for the Court’s initial determination of probable cause on the complaint.

This morning, the government moved to dismiss the cases against Collins and Robledo. The docket minutes for today’s hearing on the dismissal confirmed (as had been reported elsewhere) that the grand jury no billed an indictment against this couple.

The government provided additional bases for its motion, stating that a U.S. grand jury on 10/7/25 returned a “no bill” as to these defendants and thus declined to return an indictment against them. Further, the government confirmed on the record that the complaint affiant swore under oath that the affiant had reviewed video evidence that corroborated the complaint’s version of events, and the Court confirmed that such sworn affirmation was a substantial part of the basis for the Court’s initial determination of probable cause on the complaint.

There are, admittedly, several sealed dockets. NDIL still has not docketed the case of the alleged Latin King member charged with soliciting a plot against Greg Bovino, and if there were any unsealed charges filed against the people from the South Shore apartment raid, it’s only two guys arrested on warrants for a narcotics case in Texas that doesn’t mention any gang involvement.

But as of right now, those eleven charges of which DHS boasted have turned into two.

Greg Bovino, who promised a shitshow, is batting just 18% on remaining public charges, less than two weeks out.

Update: Here’s Block Club Chicago’s report on the dismissed charges, which includes interviews.

“I’ve been practicing law for 54 years and I’ve never had another client with no bill returned,” said Richard Kling, an attorney representing Collins. “This is a once-in-a-lifetime for me.”

[snip]

Kling said his client, who had also previously been jailed for more than two days following his arrest last month, was “obviously relieved” but he cautioned that prosecutors have said they still have 2 1/2 weeks to determine whether to pursue other charges related to the arrest.

On Wednesday, citing the adage that a grand jury could indict a ham sandwich, Kling told Block Club that prosecutors apparently had “less evidence than a ham sandwich” against his client.

“The grand jury, I hope, took the position that people have a right to protest,” Kling said. “They decided that the First Amendment is more important than criminal charges.”

Update: And … NDIL just moved to dismiss the Ivrey complaint — the one where he seemingly confessed.

Update: Once again, in dismissing the charges, Chicago judges are laying a record that the affiant in these cases did not do their due diligence.

ORDER as to Paul Ivery (1): Hearing held on the government’s motion to dismiss the complaint without prejudice (doc. # 10 ). The government provided additional bases for its motion on the record. Further, the government confirmed on the record that the complaint affiant swore under oath that the affiant had reviewed video evidence that corroborated the complaint’s version of events, and the Court confirmed that such sworn affirmation was a substantial part of the basis for the Court’s initial determination of probable cause on the complaint. The government made an oral motion to vacate the release order, noting that vacatur of the order is part and parcel of case dismissal. For the reasons stated on the record, the Court: (1) granted the oral motion to vacate the release order (doc. # 8 ), and (2) granted the motion to dismiss (doc. # 10 ) without prejudice without objection. The release order (doc. # 8 ) is vacated. The case is dismissed without prejudice. Signed by the Honorable Gabriel A. Fuentes on 10/10/2025. Mailed notice (aee, ) (Entered: 10/14/2025)