Article I: Obstruction of Congress

The Constitution provides that the House of Representatives shall have the sole Power of Impeachment and that civil Officers of the United States, including the Secretary of Homeland Security, shall be removed from Office on Impeachment for, and Conviction of, Treason, Bribery, or other high Crimes and Misdemeanors. In her conduct while Secretary of Homeland Security, Kristi Lynn Arnold Noem, in violation of her oath to support and defend the Constitution of the United States against all enemies, foreign and domestic, to bear true faith and allegiance to the same, and to well and faithfully discharge the duties of her office, has willfully and systematically refused to comply with the law, in that— (1) Kristi Lynn Arnold Noem willfully violated Public Law No. 118–47 which states no funds appropriated to Department of Homeland Security may be used to prevent a Member of Congress from entering, for the purpose of conducting oversight, any facility operated by or for the Department of Homeland Security used to detain or otherwise house aliens and to comply with Section 527 of the fiscal year 2024 Department of Homeland Security Appropriations Act, as incorporated in Public Law No. 118–47, which specifically provides that it may not be construed to require a Member of Congress to provide prior notice of the intent to enter a Department of Homeland Security facility used to detain or otherwise house noncitizens for the purpose of conducting oversight.. (2) Without any congressional revision to the text of Section 527, Kristi Lynn Arnold Noem implemented a scheme on May 13, 2025, to require notice a minimum of seven (7) calendar days in advance to schedule visits to Department of Homeland Security detention facilities, absent authorization by the Secretary. In an attempt to hide Department of Homeland Security activities, Members of Congress continued to be refused entry to Department of Homeland Security facilities in incidents such as: (A) On July 8–9, 2025, a Representative from Texas requested to visit the El Paso Service Processing Center. Immigration and Customs Enforcement refused to accommodate the July 9 oversight visit because she did not provide the required seven days’ advance notice, and she was denied entry on July 9, 2025. (B) On July 20, 2025, a Representative from Colorado attempted an oversight visit to the ICE detention facility in Aurora, Colorado. ICE denied him entry on the basis that he had not provided seven calendar days’ advance notice. (C) On July 7, 2025, a Representative from California sought to inspect the Los Angeles ICE Field Office. ICE refused to permit the visit, asserting that the facility was not a detention facility subject to Section 527 oversight, despite noncitizens being held at the facility, pursuant to Section 527. (D) On June 17, 2025, a Representative from New York attempted to visit the New York ICE Field Office. ICE refused to permit the visit, asserting that the facility was not a detention facility subject to Section 527 oversight, despite noncitizens being held at the facility, pursuant to Section 527. (E) On July 21, 2025, Representatives from Colorado, Mississippi, and Maryland arrived at the Washington ICE Field Office in Chantilly, Virginia to conduct oversight after learning that individuals were being held there. ICE refused to permit the visit, asserting that the facility was not a detention facility subject to Section 527 oversight, despite noncitizens being held at the facility, pursuant to Section 527. (F) On August 30, 2025, a Representative from Washington visited the Northwest ICE Processing Center in Tacoma, Washington to conduct Congressional oversight. Upon arrival, they were denied entry without explanation. (3) Kristi Lynn Arnold Noem’s willfully violated the Impoundment Control Act of 1974 where, under her supervision, the Federal Emergency Management Agency withheld funds obligated by Congress. According to Government Accountability Office report B–337204.2, FEMA withheld funding for the Emergency Food and Shelter Program and the Shelter and Services Program in violation of the Impoundment Control Act. When the Government Accountability Office contacted Secretary Noem, her team refused to provide additional information on the funds withheld.