D.C. Circuit Vacates Contempt Proceedings in Tren de Aragua Deportation Case
The U.S. Court of Appeals for the D.C. Circuit ruled 2-1 that a district court's contempt proceedings against government officials over Tren de Aragua deportations constitute an abuse of discretion. The decision addresses events from March 2025 involving the removal of alleged gang members to El Salvador.
Ministry of Defense of Ukraine / Wikimedia (CC BY-SA 2.0)U.S. C. Circuit issued a 2-1 decision in the case In re Trump, vacating a district court's orders related to contempt proceedings. The ruling, delivered on April 14, 2026, addresses the government's deportation of alleged members of Tren de Aragua, a Venezuelan criminal gang designated as a foreign terrorist organization.
More than a year prior, the President invoked the Alien Enemies Act to detain and remove such individuals from the United States. On March 15, 2025, the government placed a group of alleged gang members, including the plaintiffs in the case, on planes to El Salvador.
U.S. airspace, the district court issued an order prohibiting the removal of the plaintiffs from the United States. The Supreme Court later vacated this order, citing a legal error and improper venue for the plaintiffs' suit. Despite the vacatur, the district court proceeded to threaten criminal contempt against government officials for non-compliance with the now-invalid order.
Examples included requirements to regain custody of the plaintiffs. C. Circuit previously issued a writ of mandamus to vacate the initial contempt order.
The district court continued with contempt proceedings regarding the government's transfer of the plaintiffs to El Salvador's custody.
The government identified the official responsible for the transfer decision. The district court had indicated that this identification was sufficient for a prosecution referral but later expanded its inquiry. The expanded proceedings ordered hearings to obtain additional details from government counsel about the March 2025 events.
The majority opinion stated that these actions represent a clear abuse of discretion. The original district court order did not address transferring custody, lacking the clarity needed for criminal contempt based on that action. Further, the government had already provided the necessary information by naming the responsible official, making additional investigation unnecessary.
