The FBI Thinks Renee Good's Anti-ICE Activism Is Relevant in Deciding Whether Killing Her Was Justified
It is hard to see how, since that question hinges on what happened the morning that an ICE agent shot her.
A few hours after an immigration agent fatally shot Renee Good in Minneapolis last Wednesday, Secretary of Homeland Security Kristi Noem said the 37-year-old activist was engaged in "domestic terrorism" at the time of her death. "This is classic terrorism," Vice President J.D. Vance agreed the next day. Noem reiterated that description during a contentious interview with CNN's Jake Tapper on Sunday, saying, "If you look at what the definition of domestic terrorism is, it completely fits the situation on the ground."
FBI agents charged with investigating the shooting reportedly are now trying to support that characterization by examining Good's ties to groups that oppose the Immigration and Customs Enforcement (ICE) crackdown in Minneapolis. Federal investigators are also looking into protest activities by Good's widow, who was with her when ICE agent Jonathan Ross killed her. That focus on anti-ICE activism, which on Tuesday prompted the resignation of six career prosecutors in the U.S. Attorney's Office for the District of Minnesota, raises new questions about a probe that is supposed to determine whether Ross' use of deadly force was legally justified.
The reliability of that investigation was already in doubt for two reasons. First, Noem, Vance, and President Donald Trump have prejudged the outcome by declaring that Ross acted in self-defense. Second, Drew Evans, superintendent of the Minnesota Bureau of Criminal Apprehension, complained that the U.S. Attorney's Office, after initially indicating that his agency would be included in the investigation, reversed course, saying the probe "would now be led solely by the FBI."
The FBI's interest in Good's history of activism suggests an attempt to obscure the central legal issue raised by the shooting: Did Ross reasonably believe, given "the totality of the circumstances," that shooting Good was necessary to protect himself, his colleagues, or the general public from the threat she allegedly posed when she began to drive away after she was confronted by ICE agents who ordered her to get out of her car? The FBI's investigative tangent also raises the question of exactly what Noem and Vance mean by "domestic terrorism"—in particular, whether they define that term so broadly that it includes conduct protected by the First Amendment. Spoiler alert: They do.
On the day of the shooting, Noem said Good was a domestic terrorist because she "weaponize[d] her vehicle" by "attempt[ing] to run a law enforcement officer over," which "appear[ed] to be an attempt to kill or to cause bodily harm to [ICE] agents." She said Ross, "fearing for his life and the other officers around him and the safety of the public," fired "defensive shots." Vance concurred that Ross "fired in self defense" because "his life was endangered." But he also tied Good to anti-ICE protesters who are "assaulting and inciting violence against our law enforcement officers," declaring that "we're not going to give in to terrorism."
That terrorism, Vance averred, included "people trying to antagonize" ICE agents as well as people committing "acts of violence" such as "throw[ing] bricks" or firing guns. "Sometimes they dox them," he added. "Sometimes they go to their place of residence and harass their families. This is classic terrorism."
Is it? Under federal law, "domestic terrorism" involves criminal acts "dangerous to human life" that aim to "intimidate or coerce a civilian population," "influence the policy of a government by intimidation or coercion," or "affect the conduct of a government by mass destruction, assassination, or kidnapping."
Some of the actions that Vance described, such as lobbing bricks at ICE agents or shooting at them, fit that definition. But other tactics he mentioned, such as revealing the identities of ICE agents or "trying to antagonize" them in unspecified ways, sound like constitutionally protected speech.
As Reason's C.J. Ciaramella notes, Noem likewise has sought to expand the definition of domestic terrorism. Speaking to reporters last July, she said "violence" against ICE agents is "anything that threatens them and their safety," such as "doxing them" or "videotaping them where they're at when they're out on operations." Publicizing ICE operations qualifies as "violence," she suggested, because it "encourag[es] other people to come and to throw things" such as "rocks" and "bottles."
That view is consistent with Attorney General Pam Bondi's take. In a December 4 memo to federal prosecutors aimed at "countering domestic terrorism," Bondi echoed Trump's concern about the left-wing beliefs he blames for inspiring political violence. She quoted the statutory definition of domestic terrorism but then stretched it to include "organized doxing of law enforcement," "impeding" federal officers, and unspecified "targeting of public officials or other political actors."
Noem's department defines such "terrorism" broadly. Ciaramella notes that Tricia McLaughlin, assistant secretary for public affairs at the Department of Homeland Security (DHS), says "doxing" includes "videotaping ICE law enforcement and posting photos and videos of them online." McLaughlin added that "we will prosecute those who illegally harass ICE agents to the fullest extent of the law." Following or recording ICE agents as they perform their public duties, DHS told Ciaramella, "sure sounds like obstruction of justice."
When Noem and Vance aver that Good was involved in "domestic terrorism," in short, they are not referring merely to her alleged assault on Ross. They are talking about a broader pattern of anti-ICE activity that includes nonviolent, constitutionally protected conduct.
On the morning of the shooting, Good had positioned her Honda Pilot sideways on Portland Avenue, near several unmarked ICE vehicles. The SUV was there a few minutes before ICE agents approached it. Although Noem claimed Good "was blocking the officers in with her vehicle," bystander video shows other cars passing the SUV, using the lane that was still open. Here is how Good's widow described what she and her wife were doing in a statement to Minnesota Public Radio: "On Wednesday, January 7th, we stopped to support our neighbors. We had whistles. They [the ICE agents] had guns."
Cell phone video that Ross recorded suggests Good and her wife were involved in ongoing protests against ICE operations in Minneapolis. Good's wife, who is wearing an orange whistle around her neck, is recording Ross as he records her. "We don't change our plates every morning, just so you know," she tells Ross. "It'll be the same plate when you come talk to us later."
Online documents that Good shared with parents at her son's school, where she served on the board, reinforce the impression that her activism predated her fatal encounter with Ross. "Thank you to families who have been on ICE watch, helping to protect their neighbors," Good said in a December 16 message described by CNN. She linked to a training document that explains how to obtain those orange whistles, which protesters use to alert the neighborhood when they see ICE agents. "ICE are untrained bullies looking for easy targets," it says. "Neighbors showing up have saved lives."
That document linked to "another guide" that "stresses nonviolent responses to ICE agents, while also encouraging a refusal to 'comply with demands, requests, and orders,'" CNN reports. "It suggests 'creative tactics,' noting that 'crowds, props, traffic, and noise can make detentions difficult [and] sometimes ICE vehicles can't move ("whoops!").' It does not specifically suggest blocking operations with a vehicle."
If that is what Good was trying to do, the ICE agents had a legitimate beef with her, and so did the motorists who had to drive around her SUV that morning. But it would be quite a stretch to describe such nonviolent tactics as "domestic terrorism," and it would be even more misleading to put perfectly legal conduct such as blowing the whistle on ICE, whether literally or figuratively, in that category.
Let's assume the FBI's investigation confirms what already seems pretty clear: that Good and her wife, who moved to Minneapolis in 2025, soon became involved in anti-ICE protests there. In what way does that illuminate the question of whether Ross was legally justified in shooting her?
Noem, Vance, and Trump say Good deliberately tried to run Ross down. That seems doubtful given her pleasant demeanor in Ross' video and the fact that she was steering to the right, away from the ICE agents, when he shot her.
Noem, Vance, and Trump also say Good's car actually struck Ross, who was standing near the left headlight when the SUV began moving forward after backing up a bit. It is hard to tell from the video evidence whether that is true, although it seems clear that any injury he suffered must have been pretty minor, since he is seen walking around without obvious difficulty after the shooting.*
Neither point is crucial in determining whether this use of force was "objectively reasonable." Even if Good was simply trying to leave rather than trying to assault Ross, and regardless of whether the car made contact with him, it would have been reasonable for him to worry about his safety when the SUV began moving, since he had positioned himself (contrary to standard police training) in front of the vehicle.
Ross quickly moved out of the way, the solution that the Justice Department recommends in situations like this. It's not clear whether he was still in the vehicle's path when he fired the first shot, which hit the lower left corner of the windshield. But he was clearly not in the SUV's path when he fired the second and third shots, which entered the car through the front window on the driver's side. When Tapper asked Noem about the justification for those shots, she noted that Ross was making a "split-second" decision, which might count in his favor even if that decision seems mistaken in retrospect.
That's assuming it made sense to think shooting Good was an effective way to neutralize the threat her car allegedly posed. The actual result was that the SUV careened down the street without guidance, stopping only after it crashed into a car parked on the left side. If anything, Ross aggravated any danger the car may have posed by killing the person who was steering it.
However you weigh those factors, Good's opinions about immigration enforcement, as reflected in her prior activism, seem irrelevant in assessing Ross' conduct. Even if she was a committed anti-ICE activist (as the documents described by CNN suggest), that hardly means she was bent on killing an immigration agent with her car. And at the time, Ross knew nothing about Good's background, so that information could not possibly have influenced his perception of the danger she posed.
"There's nothing in there that suggests attacking ICE agents or engaging in any other form of physical harm or property damage," William and Mary law professor Timothy Zick, the author of a book about the right to protest, told CNN. "This is Authoritarianism 101, where you blame the dissenters and the activists for causing their own death."
Trump reinforced that impression on Sunday. "At a very minimum," he told reporters, "that woman was very, very disrespectful to law enforcement." Good's decision to disregard an ICE agent's order to "get out of the fucking car" certainly seems reckless, especially in retrospect, but it surely was not a capital offense. And more generally, her "disrespectful" attitude toward ICE, which the FBI seems bent on confirming, tells us nothing about the legal justification for killing her.
*Addendum: On Wednesday, the New York Post, citing an unnamed DHS official, reported that Ross "suffered internal bleeding after being clipped," adding that the official "did not elaborate on how severe the internal bleeding was." CBS News likewise said "it was unclear how extensive the bleeding was," noting that Ross was treated at a hospital and released the same day.
