Case 1:25-cv-02412 Document 1 Filed 03/24/25
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5.
Mere days later, however, the federal government began a series of unlawful efforts
to arrest, detain, and remove Ms. Chung from the country because of her protected speech. It now
appears that an ICE official signed an administrative arrest warrant for Ms. Chung on March 8,
2025. On March 9, 2025, Immigration and Customs Enforcement (ICE) showed up at Ms. Chung’s
parents’ residence seeking her. On March 10, 2025, a federal law enforcement official advised Ms.
Chung’s counsel that her lawful permanent resident status is being “revoked.” On Thursday, March
13, 2025, federal law enforcement agents executed a judicial search warrant at two Columbia-
owned residences, including Ms. Chung’s dormitory, seeking documents, including any
occupancy or lease agreements, travel records, and immigration records—even though the warrant
ostensibly targeted Columbia itself, not Ms. Chung.
6. ICE’s shocking actions against Ms. Chung form part of a larger pattern of attempted
U.S. government repression of constitutionally protected protest activity and other forms of
speech. The government’s repression has focused specifically on university students who speak
out in solidarity with Palestinians and who are critical of the Israeli government’s ongoing military
campaign in Gaza or the pro-Israeli policies of the U.S. government and other U.S. institutions.²
Now, officials at the highest echelons of government are attempting to use
immigration enforcement as a bludgeon to suppress speech that they dislike, including Ms.
Chung’s speech. To this end, Defendants-Respondents have adopted a policy (“the Policy”) to
retaliate against and punish noncitizens like Ms. Chung for their participation in protests. Under
7.
2 See, e.g., Bianca Quilantan, Madine Touré, ‘They need to see the institutions experiencing pain’: The Trump
administration wants Columbia University to change its admissions and disciplinary rules before research money gets
turned back on., Politico (Mar. 15, 2025), available at https://www.politico.com/news/2025/03/15/colleges-federal-
funding-shock-trump-antisemitism-00231160; Kate Bellows, Can Trump Force Columbia U. to Expel Student
Protesters?, Chronicle of Higher Education (Mar. 14, 2025), available at https://www.chronicle.com/article/can-
trump-force-columbia-u-to-expel-student-protesters; Kanishka Singh, Jonathan Allen, Trump Threatens Funding Cut
to Colleges Allowing ‘Illegal Protests’, Reuters (Mar. 4, 2025), available at https://www.reuters.com/world/us/trump-
says-federal-funding-will-stop-colleges-schools-allowing-illegal-protests-2025-03-04/.
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