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![PRELIMINARY STATEMENT
On March 12, 2025, agents from the Department of Homeland Security ("DHS") "seized
Abrego I] without any lawful authority." Abrego Garcia v. Noem, 777 F. Supp. 3d 501, 519 (D.
Md. 2025). Mr. Abrego was taken to an Immigration and Customs Enforcement ("ICE") field
office, where federal agents interviewed him in connection with an investigation into suspected
human smuggling without properly advising him of his Miranda rights and without a translator
present. A few days later, DHS unlawfully removed Mr. Abrego to El Salvador.
The government's conduct on March 12 violated Mr. Abrego's Fourth and Fifth
Amendment rights. Because of this flagrant abuse of law enforcement authority, we move to
suppress the statements that Mr. Abrego made to law enforcement when he was unlawfully
arrested and detained.
BACKGROUND
Mr. Abrego's Arrest on March 12, 2025
When the government arrested Mr. Abrego on March 12, 2025, prior to removing him to
El Salvador, he was lawfully living and working in Maryland. See Abrego Garcia v. Noem, No.
25 Civ. 951, 2025 WL 2062203, at *3 (D. Md. July 23, 2025). In 2019, Mr. Abrego secured an
order from an immigration court granting him withholding of removal to El Salvador. (D. Md.
Am. Compl. 19 1, 48, 70-72; see also Compl. Ex. B).' The government never appealed the
withholding decision, nor did it seek to remove him to a third country at the time. Id.; see 8 C.F.R.](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:t4x2ruk2qmob2b2cx55h4v7r/bafkreifya4rdxfz4firfxfl5wli2vfoyfttfy5cdecunr64rgpzeeyo4mi@jpeg)
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