Article II: Violation of public trust

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 well and faithfully discharge the duties of her office, has breached the public trust, in that: (1) Kristi Lynn Arnold Noem has repeatedly violated the Immigration and Nationality Act, the First and Fourth Amendments of the United States Constitution, and due process rights of American citizens by directing Immigration and Customs Enforcement to make widespread warrantless arrests, forgo due process, and use violence against United States citizens, lawful residents, and other individuals. Kristi Lynn Arnold Noem engaged in this conduct by the following means. (A) In October 2025, a United States District Court Judge from the Northern District of Illinois found that Immigration and Customs Enforcement had arrested 22 individuals without a warrant in violation of the Castañon Nava settlement agreement in early 2025. (B) In September of 2025, ICE raided 7500 S. South Shore Drive in Chicago, claiming that the building was occupied by members of the transnational crime organization, Tren de Aragua. During the warrantless raid, Federal agents used military-style tactics to raid apartments, dragging United States citizens, military veterans, and seniors out of their apartments in zip ties and detaining residents, several U.S. citizens, for hours. After the raid, residents returned to damaged apartments and stolen items. (C) On October 22, 2025, ICE agents used tear gas on children having a Halloween parade in Chicago, violating order No. 25 C 12173 issued by U.S. District Court Judge, Sara Ellis restricting ICE and Customs and Border Protection agents from using non-lethal munitions without warning and justification. Another violation of U.S. District Judge Ellis’ order came on October 14, 2025, ICE and CBP agents used tear gas on a peaceful crowd. The crowd had formed after a Federal agent crashed into a vehicle. After Chicago police arrived on the scene, responding to reports of a car accident, ICE agents deployed tear gas on residential streets and near a grocery store. This exposed police officers, elderly adults, and children as young as 1 to harmful gases. (D) Masked and militarized patrols of Federal agents have taken to the streets of Chicago as part of Operation Midway Blitz in a systemic violation of rights at the direction of Kristi Lynn Arnold Noem. These agents used excessive force, including, shooting an unarmed United States citizen in Chicago who was part of a convoy of civilian vehicles following Federal agents. According to body camera footage, an agent driving next to the vehicles was yelling obscenities and struck the victim’s car—proceeding to fire five shots at the unarmed driver. The Department of Homeland Security, under Kristi Lynn Arnold Noem, falsely accused the victims of aggressively driving into the Federal agents despite video evidence. (E) On January 7, 2026, an ICE agent fired his weapon at a vehicle attempting to get out of the way of agents, killing the driver, a U.S. Citizen. Despite video showing the officer on the side of the vehicle while firing and the vehicle was moving away from the officer on the second and third shots, Kristi Lynn Arnold Noem is claiming publicly that the officer was in danger and in front of the vehicle when he fired.