The Federal Government Used Jawboning to Censor ICE Transparency Initiatives–Rosado v. Bondi
Jawboning is government coercion to suppress constitutionally protected speech. (This is distinguishable from direct censorship, where the government bans or restricts that speech expressly). If asked, many people would say they oppose jawboning. However, most of those opponents cannot properly identify the facts that distinguish jawboning from ordinary government functions. This enables jawboning to be weaponized. Bad faith actors can intentionally mischaracterize legitimate government efforts as censorial jawboning, and simultaneously excuse abusive government censorial strong-arming as not jawboning; in each case, preying on the public’s lack of understanding about what is and isn’t impermissible censorship.
If you think the courts always curb these abuses, recall Judge Doughty’s 155 page MAGA screed against the Biden administration’s purported jawboning, “patriotically” issued on July 4, 2023. Judge Doughty claimed he was redressing the “most massive attack against free speech in United States’ history,” only to be badly exposed as a partisan hack/fool when the Supreme Court reviewed those facts.
MAGA culture warriors have repeatedly decried Biden-era jawboning, but far worse behavior from the Trump administration is often just downplayed as no big deal or kakistocrats being kakistocrats. Techdirt covers this duality/hypocrisy. We should not grade the Trump administration’s censorship on some sort of downward-adjusted curve. As this case illustrates, the Trump 2.0 administration has been unstintingly and gleefully censorial, both expressly and using indirect means like jawboning.
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This case involves former-AG Bondi and former-Secretary Kristi Noem. Both of them arrogantly thought they could successfully navigate having the famously mercurial and unreasonable Trump as a boss. Instead, both of them transactionally served as Trump’s use-and-discard useful idiots and have been shitcanned.
This case is part of the detritus of shadow president Stephen Miller’s highly unpopular deployment of ICE as a weapon against the American public. In response, truly patriotic Americans self-organized to fight back against ICE’s abuses, including providing online tools to track, document, and push back against ICE.
“Plaintiff Kassandra Rosado created ‘ICE Sightings – Chicagoland’ in January 2025 as a
Facebook group for people to post videos and information regarding ICE activity.” LARPing as a concerned American 🙄, Laura Loomer (a well-known figure on this blog) publicly flagged the group for Bondi and Noem. Bondi responded that the DOJ got Facebook to remove the group:
Noem responded almost identically:
[Another semantic note: like the term “jawboning,” the term “doxxing” is ambiguous and weaponizable. Bondi and Noem falsely claimed that citizens’ efforts to increase the transparency of government activities constituted nefarious or even illegal “doxxing,” when it’s really the kind of power-checking efforts our country was founded on.]
In a second jawboning incident,
Plaintiff Kreisau Group created “Eyes Up” in August 2025 as a phone application for people to post videos and information regarding ICE activity. Around October 2, 2025, Apple removed several apps that shared information regarding ICE activity, including ICEBlock, Red Dot, and Eyes Up. Speaking to Fox News on October 2, Defendant Bondi stated: “We reached out to Apple today demanding they remove the ICEBlock app from their App Store – and Apple did so.” And on October 8 Bondi made a public statement that “we had Apple and Google take down the ICEBlock apps.”
Apple informed Kreisau Group that Apple had removed Eyes Up from the App Store after receiving “information” from “law enforcement” that the app violated Apple’s guidelines. Apple stated that the app violated guideline 1.1.1, which prohibits “defamatory, discriminatory, or mean-spirited content.” But Apple had previously and independently reviewed Eyes Up in August 2025. During that previous review, Eyes Up was already available on its website, and Apple had knowledge of the purpose of Eyes Up, of actual videos available on it, and how it worked.
Traceability
The court is satisfied with the allegations of the federal government’s responsibility for the removals:
First, Facebook had previously reviewed the Chicagoland group, and Apple had previously reviewed Eyes Up. In both cases, Facebook and Apple had determined that the content met their requirements. Second, Facebook and Apple changed their positions and removed the content immediately after Defendants contacted them about it. And third, Defendants made public statements taking credit for the fact that Facebook and Apple had removed the content.
Injunction Merits
The court says there’s enough evidence to enjoin the censorship:
[Bondi and Noem] reached out to Facebook and Apple and demanded, rather than requested, that Facebook and Apple censor Plaintiff’s speech. See R. 10-4 at 29 (“‘We reached out to Apple today demanding they remove the ICEBlock app from their App Store – and Apple did so,’ Bondi said in a statement to Fox News Digital.”); R. 10-4 at 36 (emphasis added) (Loomer posting on social media that “DOJ source tells me . . . they have contacted Facebook . . . to tell them they need to remove these ICE tracking pages.”); R. 10-4 at 65 (Noem posting on social media that “[p]latforms like Facebook must be PROACTIVE [sic] in stopping the doxxing of our [ICE] law enforcement.”).
Bondi and Noem also intimated that Facebook and Apple may be subject to prosecution for failing to comply with Bondi and Noem’s demands. For example, after stating that we “had Apple and Google take down the ICEBlock apps,” Bondi further stated: “We’re not going to stop at just arresting the violent criminals we can see in the streets.” And in the same social media post where Noem wrote that “[p]latforms like Facebook must be PROACTIVE in stopping the doxxing of our [ICE] law enforcement,” she added: “We will prosecute those who dox our agents to the fullest extent of the law.” Although these statements may not be direct threats to prosecute Facebook and Apple, they are intimations of a threat. And thinly veiled threats such as these constitute sufficient evidence on which Plaintiffs are likely to succeed on their claim. [cite to Bantam Books]
The judge didn’t set the precise terms of the injunction (that will happen soon). However, the judge cannot compel Facebook or Apple to restore ICE Sightings or Eyes Up. Restoring the services is, after all, their editorial prerogative. Indeed, there’s no guarantee the services will be restored. As discussed below, both Facebook and Apple have repeatedly and expressly prioritized their fealty to government censors over serving their audiences. Thus, either way, the government has already won the case by sidelining two ICE accountability tools for many months–and possibly indefinitely. This would have been a good enough reason to fire Bondi and Noem, but oops, Trump already did that for far less legitimate reasons.
Implications
This is not a difficult case legally or factually. The court didn’t need to engage in any nuanced inquiry or explore subtle differences between government requests and coercion. Bondi and Noem wanted the Facebook group and apps gone. They told Facebook and Apple to remove them and coupled that instruction with promises to exercise their enforcement powers. This is a textbook example of censorship via jawboning.
The bigger question is: why did we get such a clean example of jawboning? Typically, government officials would not have made their censorship demands so brazenly; nor would government officials take a very public celebratory victory lap after executing their censorship. Imagine a counterfactual where Bondi and Noem simply posted a thank you to Facebook and Apple for helping ICE out. Would that have changed the outcome?
So why didn’t Bondi and Noem execute their goals more smartly? An Occam’s Razor guess is that they are incompetent. A realpolitik guess is that Bondi and Noem only cared about a single-person audience, Pres. Trump. They needed to very visibly demonstrate their censorship in order for Trump to recognize and appreciate it. An darker guess is that Bondi and Noem didn’t fear any repercussions from abusing their government position. Indeed, other than their shitcanning (which was inevitable from the first day they took the positions), I doubt Bondi or Noem will suffer any personal consequences for any of their misdeeds in office.
While Bondi and Noem (and Stephen Miller and ICE) are the real villains in this story, let’s not overlook Facebook and Apple’s complicity. Facebook and Apple showed zero backbone in the face of Bondi and Noem’s unreasonable demands. The companies willingly served as useful idiots to the censors. Their spinelessness is not new; recall how Apple and Google didn’t do a damn thing to push back against the TikTok ban, even though it stripped away their editorial discretion. Apple and Facebook lack any editorial integrity and have intentionally decided to placate MAGA censors instead. That deserves more condemnation than the court can provide.
Case Citation: Rosado v. Bondi, 2026 WL 104778 (N.D. Ill. April 17, 2026)
BONUS: Along similar lines as the Rosado case, see Oregon v. RFK Jr., 6:25-cv-02409-MTK (D. Ore. April 18, 2026), where the judge unloads on RFK Jr. for threatening to block all federal funding to hospitals if they provided any gender-affirming care. I thought this quote from the judge was really beautiful:
Secretary Kennedy’s unlawful declaration harmed children. This case illustrates that when a leader acts without authority and in the absence of the rule of law, he acts with cruelty.
Selected Jawboning Posts
- COVID Jawboning Lawsuit Dismissed (For Now)–Dressen v. Flaherty
- Section 230 (Still) Applies to Contract Breach Claim–NJCCC v. McAleer
- Facebook Defeats Armslist’s Account Termination Lawsuit–Armslist v. Facebook
- Robert F. Kennedy Jr. Is Breaking Internet Law Faster Than I Can Blog It
- Plaintiffs Lack Standing to Sue Over Government Jawboning When Their Evidence is Based on Vibes–Murthy v. Missouri
- Jawboning Defendants Are 6-for-6 in the Ninth Circuit–Hart v. Facebook
- Another Jawboning Case Fails in the 9th Circuit (But a TAFS Judge Doesn’t Like the Biden Administration)–Rogalinksi v. Meta
- Sixth Circuit Dismisses Online Jawboning Case–Changizi v. DHHS
- “Twitter Files” Don’t Help Revive Jawboning Case–Hart v. Facebook
- Another Jawboning Case Fails in the Ninth Circuit–Kennedy v. Warren
- Government Submissions to a Trusted Flagger Program Aren’t Unconstitutional Jawboning–O’Handley v. Weber
- Ninth Circuit Easily Rejects Another Jawboning Case–Huber v. Biden
- Ninth Circuit Easily Rejects Jawboning Claims Against YouTube–Doe v. Google
- Facebook Defeats Jawboning Lawsuit Over COVID Misinformation Removal–Rogalinski v. Meta
- COVID Skeptics’ Anti-Jawboning Lawsuit Fails–Changizi v. Department of HHS
- Facebook & Twitter Defeat Lawsuit Over Account Terminations of COVID/Mask Skeptic–Hart v. Facebook
- Twitter Defeats Trump’s Deplatforming Lawsuit–Trump v. Twitter
- Section 230 Survives Yet Another Constitutional Challenge–Huber v. Biden
- Another Anti-Vaxxer Jawboning Lawsuit Fails–ICAN v. YouTube
- The First Amendment Protects Twitter’s Fact-Checking and Account Suspension Decisions–O’Handley v. Padilla
- One More Time: Facebook Isn’t a State Actor–Atkinson v. Facebook
- Government Jawboning Doesn’t Turn Internet Services into State Actors–Doe v. Google
- Facebook Defeats Lawsuit By Publishers of Vaccine (Mis?)information–Children’s Health Defense v. Facebook
- Another Must-Carry Lawsuit Against YouTube Fails–Daniels v Alphabet
- Congressional Jawboning of Internet Services Isn’t Actionable–AAPS v. Schiff
- Facebook Isn’t a Constructive Public Trust–Cameron Atkinson v. Facebook
- Section 230 Ends Demonetized YouTuber’s Lawsuit–Lewis v. Google


