In a courtroom in downtown Chicago on Tuesday, a federal judge admonished Gregory Bovino, a senior Border Patrol official who has become a face of the Trump administration’s crackdown on illegal immigration, for his agency’s use of force and tear gas in Chicago in recent weeks.
For more than an hour, the judge, Sara L. Ellis of Federal District Court for the Northern District of Illinois, read Mr. Bovino restrictions she had previously set as part of a lawsuit over tactics that agents are using and cited examples of times his agents appeared to violate those restrictions.
They used tear gas in a neighborhood where children were about to march in a Halloween parade, Judge Ellis said. They failed to warn residents before tossing tear gas canisters at them, she said, noting an incident in which an agent threw a canister out of a car as it drove away.
The judge then ordered Mr. Bovino, who took the stand in his usual green fatigues and Border Patrol insignia, to appear at the federal courthouse at the end of every weekday to personally provide her with a report on the day’s arrests and incidents.
Mr. Bovino walked through a crowd of journalists and protesters as he entered the Dirksen Federal Building in Chicago on Tuesday.Credit...Jamie Kelter Davis/Getty Images
“I’ll see you tomorrow at 6,” she said, before telling Mr. Bovino that he could get back to work.
The hearing offered Mr. Bovino little opportunity to broadly defend the Trump administration’s immigration crackdown in Chicago, which began in early September and has resulted in at least 3,000 arrests, according to the administration. Judge Ellis asked Mr. Bovino few detailed questions and did nearly all of the talking throughout the hearing, reminding Mr. Bovino of the particulars of the temporary restraining order she issued early this month limiting the use of tear gas.
Mr. Bovino answered some questions with a simple “Yes, ma’am.” Asked whether he was on the same page as the judge, he said, “I understand what you’re saying, Your Honor,” and added, “We’re on the same page, that we will abide by the T.R.O.”
Judge Ellis’s earlier order barred federal immigration agents from deploying tear gas and other chemical agents on a crowd without first issuing two warnings. She also barred agents from “deploying these weapons above the head of the crowd” in most situations.
The judge’s order left room for exceptions in cases where issuing such warnings was not feasible, or those in which someone posed a serious threat to officers or others.
The issue first came before Judge Ellis when a coalition of media organizations, protesters and clergy members filed a lawsuit accusing federal agents of “a pattern of extreme brutality” intended to “silence the press and civilians.” Outside a federal detention facility in Broadview, Ill., federal agents shot pepper balls and tear gas at protesters who gathered regularly to hold demonstrations.
As the weeks have gone on, the use of tear gas along residential streets, in particular, has become a point of contention.
In interviews and on social media, Mr. Bovino has been a forceful defender of the immigration crackdown and the work of the Border Patrol, which has more than 200 agents deployed in Chicago.
Even after the order, which was issued on Oct. 9, the Border Patrol continued to use tear gas, including in residential neighborhoods late last week and over the weekend. In several cases, residents said, no warnings were given.
A lawyer for the government said that when Border Patrol agents had used tear gas, it was in response to volatile situations. But a lawyer for the plaintiffs said that agents were inciting violence and then using it to justify more force.
Judge Ellis, who was nominated to the federal bench by President Barack Obama, seemed particularly incensed by an incident on Saturday, when agents used tear gas as they were confronted by angry residents of Old Irving Park, a Northwest Side neighborhood, not long before a Halloween parade was to step off.
You may not know Chicago’s neighborhoods, she told Mr. Bovino, explaining that Old Irving Park was a quiet area with many families and children.
“These kids, you can imagine, their sense of safety was shattered on Saturday,” she said. “And it’s going to take a long time for that to come back, if ever.”
She also questioned him about his own use of tear gas, after he was recorded on video lobbing a canister of gas last week into a group of angry residents of Little Village, on the city’s Southwest Side.
Mr. Bovino nodded when Judge Ellis noted that he had thrown the tear gas, and she told him that a warning must always be issued before chemical agents are used.
“The warning has to be, ‘I’m going to deploy tear gas,’” she said. “The warning really has to be, include what it is that you’re going to do before you do it, and allow people time to comply.”
Answering questions from the judge, Mr. Bovino said that he would ensure that all Border Patrol agents working in the Chicago immigration crackdown had body-worn cameras, recording any tactics used.
He acknowledged that he did not use a body-worn camera himself, but promised to do so by the end of the week.
“We can get a camera by Friday,” he said.
In a statement last week, the Department of Homeland Security said that the tear gas measures in one incident were necessary after agents were “swarmed by agitators.”
“The agitators obstructed federal law enforcement and ignored multiple warnings to disperse and continued to impede operations, including trying to deflate a vehicle’s tire,” the statement said. “Agents deployed crowd control measures to disperse the crowd and agitators began throwing objects at them.”
Several people have been seen pushing back physically on federal agents.
In a video filmed over the weekend, a woman could be seen shoving an agent and grabbing his cloth face mask before he pushed her to the ground.
Several people have been seen pushing back physically on federal agents.
In a video filmed over the weekend, a woman could be seen shoving an agent and grabbing his cloth face mask before he pushed her to the ground.
“I don’t know that we’re going to see a whole lot of tear gas being deployed over the next week,” she said.
Outside the courthouse on Tuesday, a small group of protesters had gathered for hours, holding signs and denouncing the tactics of immigration agents. After the hearing, Mr. Bovino left the courthouse surrounded by about two dozen Border Patrol agents, cutting through a gantlet of shouting demonstrators and driving away, leading a convoy of government vehicles.
Jamie Leventhal contributed video editing. Robert Chiarito contributed reporting.
Julie Bosman is the Chicago bureau chief for The Times, writing and reporting stories from around the Midwest.
A version of this article appears in print on Oct. 29, 2025, Section A, Page 17 of the New York edition with the headline: U.S. Judge in Chicago Orders Border Patrol Leader to Report Daily.
