Homeland Security Secretary Kristi Noem described the actions of Renee Nicole Good, the Minneapolis woman killed by Immigration and Customs Enforcement (ICE) agents on Wednesday, as “domestic terrorism.”
Nomu said Good did not comply with commands to get out of the car.[d] Minnesota authorities disputed Noem’s account, citing video that showed Good attempting to flee in her car.
Minnesota Democratic-Farmer-Labor Attorney General Keith Ellison said Thursday on CNN News Channel that Noem’s comments were an “abuse of the term” “domestic terrorism.”
President Donald Trump’s administration has placed greater emphasis on the term in recent months, including during an immigration-related shooting in October.
In September, the administration issued a memo calling on law enforcement to prioritize threats, including “violent efforts to shut down immigration enforcement,” saying “domestic terrorists” are using violence to promote “extreme views in favor of mass immigration and open borders.” Experts said this violated free speech laws.
Good, a mother of three and a poet, lived in the Minneapolis area where she was shot and killed. She was a U.S. citizen and had no criminal history, the Associated Press reported. Good’s ex-husband told the AP that she was not an activist and did not know she was participating in the protests. Good was driving home after dropping her 6-year-old son off at school when she encountered ICE.
The Trump administration has stepped up immigration enforcement in Minneapolis in recent weeks following reports of an alleged child care funding scam involving the local Somali community.
What is “domestic terrorism”?
Federal agencies have their own definitions of “domestic terrorism.”
According to a 2020 memo, the FBI cites certain sections of the U.S. Code to define “domestic terrorism” as acts that violate federal or state criminal law and endanger human life that appear to be intended to threaten or intimidate civilians. Influencing government policy through intimidation or coercion. or to influence government action through mass destruction, assassination, or kidnapping.
The Department of Homeland Security (DHS) uses a similar definition, citing a separate statute that defines “domestic terrorism” as anything that poses a danger to human life or has the potential to destroy critical infrastructure or key resources.
The nonpartisan Congressional Research Service wrote in 2023: “Unlike foreign terrorism, the federal government does not have a mechanism to formally charge individuals with domestic terrorism, making it sometimes difficult (and sometimes controversial) to formally identify someone as a domestic terrorist.”
In 2022, Michael German, a former FBI agent and then a fellow at the Brennan Center for Justice at New York University School of Law, told PolitiFact that 51 federal laws apply to “domestic terrorism.”
After the Minneapolis shooting, German told PolitiFact, “I think there was and still is a confusion between the rhetoric and the law regarding terrorism.” “There is no law that authorizes the U.S. government to designate any group or individual in the United States as a ‘domestic terrorist.'”
The federal government regularly reviews how threats are accounted for. For example, in 2025, federal authorities sometimes used the term “nihilistic violent extremists” to describe perpetrators who do not subscribe to a particular ideology but who appear to be motivated by a desire to “gamify” real-life violence, as one expert put it. Experts told PolitiFact that the term is valid, but cautioned against overusing it or citing it to obscure other ideological motivations, such as white supremacy.
Trump administration expands on “domestic terrorism” label
The Department of Homeland Security’s rhetoric regarding Goode’s shooting is similar to another immigration-related shooting in October. Border Patrol agents shot American citizen Marimar Martinez five times during DHS’ months-long immigration crackdown in Chicago, dubbed “Operation Midway Blitz.”
A Department of Homeland Security news release described Martinez as a “domestic terrorist” who possessed a semi-automatic rifle, had a “history of undercover federal agents,” and accused him of ramming a Border Patrol agent’s vehicle with his car.
In November, a federal judge granted a motion by prosecutors to dismiss the federal charges against Martinez.
“Ultimately, after evaluating everything, we determined there were serious questions about the officers’ story,” legal analyst Joey Jackson told CNN.
Government use of the term extends beyond immigration and the Department of Homeland Security.
After the murder of conservative activist Charlie Kirk, President Trump ordered the attorney general in a Sept. 25 memo to expand the “domestic terrorism” priority to include “acts of politically motivated terrorism, such as organized poison sampling campaigns, swatting, rioting, looting, trespassing, assault, destruction of property, threats of violence, and civil insurrection.”
President Trump signed an executive order days before designating Antifa, a broad, loose coalition of left-wing activists, as a “domestic terrorist” organization.
U.S. Attorney General Pam Bondi has directed federal prosecutors and law enforcement to compile a list of groups “engaging in conduct that may constitute domestic terrorism.”
Legal experts have warned that the memo could violate the First Amendment.
“Both the order and the memo have no basis in fact and law,” said Faiza Patel, director of liberty and national security at the Brennan Center for Justice. “Acting on them violates the right to free speech and may subject individuals and groups with a range of prejudicial views to investigation and prosecution.”
Experts also point out that the memo focuses on left-wing violence. There is no mention of the politically motivated assassination of Minnesota Representative Melissa Hortman, a Democratic-Farmer-Labor member, several months ago.
“When a policy directive targets one ideological family and relegates others to footnotes, it does not pretend to be neutral,” Thomas E. Brzozowski, a former Justice Department domestic terrorism adviser, wrote on Dec. 12.
Experts raise questions about Noem’s ‘domestic terrorism’ label
Information about what happened before Good was shot is still emerging. But a frame-by-frame analysis of the video footage by The New York Times and The Washington Post found that Good’s car moved toward ICE agents, but the agents moved out of the way, allowing Good to fire at least two of the three shots from the gun from the side of the car as he swerved.
Brzozowski told PolitiFact that “I think it’s a stretch to characterize this as domestic terrorism” because Good was trying to get rid of him.
But the bigger concern, he said, is that Noem is using the term “domestic terrorism” without any actual findings prior to the investigation.
“Essentially, labeling this activity as domestic terrorism within hours of the incident effectively strips domestic terrorism of its significance,” he said, calling it “a blatantly partisan effort to label it as domestic terrorism.”
“So what is domestic terrorism? No matter what the DHS secretary says, she can label anything she wants as domestic terrorism. She’s doing it without any facts.”
Shirin Sinner, a professor at Stanford University School of Law, told PolitiFact that “deliberately ramming a vehicle for political purposes may constitute terrorism in other contexts, but the video from the Minneapolis incident shows the woman trying to flee in her car rather than hitting the ICE officer. Here, the administration’s calling her a domestic terrorist is just an attempt to smear the protester and justify her killing by the ICE officer.”
German told PolitiFact that there is no public evidence to suggest that Good “engaged in conduct that could be prosecuted under the terrorism chapter of the United States Code.”
“Therefore, for government officials to call her a domestic terrorist is unsupported by law and is completely derogatory and bigoted.”
