In Portland, Oregon, a collective of demonstrators, who identify as “peaceful protesters,” has petitioned a federal judge to prevent the Department of Homeland Security (DHS) from deploying “excessive force” near the Immigration and Customs Enforcement (ICE) headquarters in their city.

On Tuesday, these individuals submitted a 41-page document that details what they describe as an “escalating pattern of unnecessary, excessive, and indiscriminate violence” by federal agents at this location. They argue that such actions warrant the issuance of a temporary restraining order (TRO). According to the protesters, their First Amendment rights are being infringed upon as the federal government allegedly retaliates against their anti-ICE demonstrations, while pro-ICE counter-protesters seem to face no such scrutiny.

The filing, submitted to the U.S. District Court for the District of Oregon, highlights the perceived misuse of police powers. It states, “On the facts of this case, not only is there a risk that police will use their arrest power to suppress speech, but there is strong evidence that they are using their broad discretion to do just that with respect to only disfavored speech.” The document further suggests that DHS’s actions are intended to penalize the crowd for their expressions.

Included in the motion are accounts of at least 12 anti-ICE protesters, each sharing experiences of alleged violence. Among the stories is a man who claims to have sustained repeated injuries from chemical munitions fired by DHS agents, including those launched from the building’s rooftop. Additionally, an 84-year-old woman reportedly suffered a head injury from a munition, and her husband, a Vietnam War veteran, expressed that both no longer feel safe attending protests due to potential violence from federal officers.

The protesters assert their right to assemble peacefully, claiming that the “gratuitous violence” from federal agents is stripping them of this constitutional liberty. They also express concern that DHS actions pose a threat of severe harm or even fatal incidents, which they allege have occurred multiple times in recent weeks.

Broadening their critique, the protesters link their local experience to a national context, suggesting that demonstrations are intensifying across the country in response to what they describe as the Trump administration’s ongoing “brutality” against dissenting voices.

On Jan. 7, Renee Good was shot and killed by an ICE agent in Minneapolis, Minnesota, leading to outrage over ICE tactics and appearing to be a flashpoint in how many U.S. citizens see the agency. Then, on Saturday, another ICE officer shot and killed Alex Pretti in the city. Neither of them appeared on video of the incidents to be posing any harm.

The Portland, Oregon, plaintiffs also mention anti-ICE protesters in Los Angeles and Chicago being attacked by federal officers despite exhibiting nothing but nonviolence. The declarants use this context to try and illustrate how the officers’ behavior outside of the Portland ICE building is emblematic of a larger structural issue and arguing that the “repeated shooting of nonviolent protesters at the Portland ICE Building will likely keep recurring” save for a TRO.

“As is evidenced by repeated events in Portland and punctuated against the backdrop of nationwide events, we know Defendants’ violence is in no way isolated,” they write. “Likewise, statements of DHS officials and senior federal executives show that the characteristics and culture of the agency and its employees is to celebrate and prioritize violent responses over fair and diplomatic ones. Finally, Defendants have offered no assurances that the conduct will cease or change.”

The anti-ICE protesters in Portland cite former Commissioner of Customs and Border Protection Gil Kerlikowske, who served under the Obama administration, as saying “DHS has shown a repeated pattern of excessive force against everyone present at the ICE Building, including Portland police officers.”

And the plaintiffs contend that there is no accountability for officers who act out of bounds, quoting leading federal officials like Vice President JD Vance as saying officers will have “absolute immunity” for actions taken in their official capacity such as when shooting at protesters.

The requested TRO is “limited,” as the filing states, because it would only apply to the area at or around the “ICE Building” and because protesters who trespass or do not obey “lawful commands” could still be arrested. Additionally “some uses of force” would be permitted “in the face of real and imminent harm to law enforcement or others.”

The plaintiffs allege that DHS’ behavior has been a “retaliatory” attempt to deter citizens from peacefully protesting and goes against the Constitution.

“Federal courts, including this one, have repeatedly understood that Defendants’ policing escalations threaten to undermine the foundations of our democracy,” the filing states. “Courts recognize that the administration, while targeting cities and states where citizens do not support its policies, has based its actions on hyperbole not supported by facts or law.”

“Federal courts serve as the guardians of First Amendment freedoms,” they go on. “Defendants’ hostility toward people in this country exercising their First Amendment rights is palpable. Unless enjoined, heavy-handed suppression of rights will continue.”