PROOF by Seth Abramson. Published January 8, 2026
About Seth Abramson. NYT bestselling author of 20+ books. Journalist. Lawyer. Songwriter (Hounds). Art critic. Recovering professor, DJ, and “Best American” series editor. Words at CNN, CBS, BBC, HBO, PBS, NPR, CNBC, The New Yorker, The Washington Post, more.
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{Note: Readers unfamiliar with Seth Abramson’s background as a criminal defense attorney and former federal criminal investigator can find his long-form biography at this external link.}
{UPDATE at 3:09 PM ET on 1/8/26} Vice President of the United States J.D. Vance has just issued an on-camera statement revealing that Renee Good’s killer, who’s now been identified by the Minneapolis Star-Tribune as ICE agent Jonathan Ross, was traumatized by an incident six months ago in which (per Vance) he was harmed by a vehicle.
Vance’s implicit admission that Ross shouldn’t have been back in the field following this incident, as he remains deeply traumatized by it, immediately establishes a potential civil cause of action by Good’s family. It also underscores that Trump’s decision to push a mass deportation scheme that is both illegal and reckless contributed to Good’s death—as if ICE can’t take the time anymore to determine which agents remain psychologically fit to serve in the field, ICE is a danger to all Americans.}
In law enforcement, when an officer approaches a civilian vehicle with the intention of advancing either a traffic or criminal investigation—in some cases, there’s overlap between the two categories—they’re electively initiating a “constitutional event.”
A constitutional event is one that implicates the rights of a person inside the United States under the United States Constitution (as amended by the Bill of Rights).
Most constitutional events have to do with the right of persons inside the United States to be free—under the Fourth Amendment—from “unreasonable searches and seizures,” with the latter term including even the temporary detention of a person.
Both arrest and temporary detention are deemed a government “seizure” of a person.
At ICE, the authority of agents to initiate a constitutional event is limited, as indeed the authority of the agency itself is very narrow. ICE can initiate constitutional events only to the extent necessary to effectuate the agency’s statutorily authorized role: that is, immigration enforcement.
If an ICE agent needs to engage in what we would term general law enforcement activity outside their narrow remit—that is, if they must do so in order to ensure that they are able to continue pursuing their prime objective and authorization—standing ICE SOPs (“standard operating procedures”) require that they request backup from local law enforcement officers, who unlike ICE are in fact authorized to engage in general law enforcement activities.
During the second Trump administration, Donald Trump effectively declared war on state and local law enforcement in the United States by provoking a needless schism between federal law enforcement officers and their state and local counterparts. This is a very, very dangerous state of affairs, given just how much these two separate law enforcement communities need to rely on one another to keep themselves and others safe. (The simplest way of understanding this is to imagine the importance of federal, state, and local entities coordinating when the FBI is going to execute a warrant in a town; local police must be notified that the armed men storming a building inside their jurisdiction are in fact doing so lawfully.)
The proximate cause of this schism Donald Trump premeditatedly devised was an explicit determination, by the current president, that if local police departments were going to refuse to act as adjuncts to his federal executive-branch agents in enforcing federal immigration laws—something, to be clear, local police departments are in no way required to do, and which it violates the principles of federalism conservatives have claimed to support for decades to try to force them to do—then he and his aides, such as Kristi Noem and her boyfriend/handler Corey Lewandowki at DHS (see prior Proof coverage of this dynamic), are “justified” in perverting the training of new ICE officers to indicate to them that they in fact do have general law enforcement powers.
Do they actually have such powers?
Again, no.
But President Trump has publicly promised to pardon and otherwise protect federal agents who act violently while advancing his agenda, and top officials at DHS have repeatedly misidentified what sort of civilian conduct legally qualifies as impeding the work of a federal agent, so the natural result of these words from Trump and Noem and others in the administration has been to give ICE agents a bewilderingly counterfactual understanding of their remit, their authority, and their task. A breathtakingly false one, even. And it is that very misunderstanding—a calculated and decidedly partisan one—that cost Renee Good her life yesterday in Minneapolis.
As most Proof readers will know, the training time of ICE officers has been reduced by 50% or more—and the prerequisites for employment by ICE have been dropped to almost nothing—even as the bosses of these agents, inside DHS and the White House, are publicly declaiming a view of what constitutes interfering in ICE operations and when ICE can detain American citizens that simply has no basis in law whatsoever.
While we only have video of the last 90% or so of the killing of poet and mother Good in Minnesota—the late 37-year-old appears to have had no prior record, and has been spoken of glowingly by friends and neighbors in multiple states (indeed to a degree that is unusual even following tragedies of this sort)—what the video shows is two officers in an unmarked pickup truck, both of them fully masked, stopping the said unmarked vehicle in the middle of a city street, quickly getting out of that vehicle, and then, with a third, largely masked agent—the killer here—moving quickly toward Good’s vehicle.
One of the fully masked ICE agents, the apparent leader of the group, has his hand outstretched in preparation of ripping opening the driver’s-side door of that vehicle.
In the view of any “reasonable person”—an objective legal standard—we’d presume that this lead ICE agent either intended to drag Good from her vehicle or to reach into her vehicle to manually turn it off against her will.
So, to be very clear, the situation was already well off the rails at this point.
Why?
Well, first and foremost, before we even get to on-street events, none of these officers should have been masked or in unmarked vehicles. And why were they masked and in unmarked vehicles? As to the former, it’s because the new Trump-era ICE policies supporting maximal aggression by ICE agents (to include actions clearly outside their remit) also explicitly condone agents masking in order to ensure they avoid responsibility or accountability for their actions. Indeed, this masking authorization is inextricably entwined with the idea the Trump administration has that their agents are going to be doing things no ICE agent has before, including things that could lead to widespread fear and anxiety and even mass civil unrest. So ICE agents preemptively hide their identities to give themselves the courage to do the things the Trump administration demands they do and has expressly given them license to do, whether legal or illegal.
And ICE agents are using unmarked vehicles en masse because the sheer scale of the deportation scheme Trump is advancing—which sets impossible-to-meet daily quotas and falls well outside what Trump told Americans he was planning to do when he ran for President of the United States in 2024 (he said he would only deport “the worst of the worst,” i.e. people with violent criminal records, a policy most Americans support, when in fact he was planning, with Russ Vought of Project 2025 and Stephen Miller, to deport every undocumented person in America and indeed focus ICE actions on those civilians ICE can most easily capture, that being law-abiding working persons without any record)—means ICE doesn’t have sufficient vehicles that are properly marked to do the immigration enforcement work it’s now doing on a daily basis. And worse, it’s doing its work almost exclusively in American cities that don’t want ICE to be present, as Trump’s immigration policy is as much about terrorizing “blue” Americans as anything else.
The result of all the foregoing is that ICE is initiating more constitutional events than ever before, under circumstances unlike any before, with less justification than we’ve ever imagined or seen, and doing so via transportation and identification procedures that ensure that the people they approach with naked aggression will be (a) terrified, and (b) as inexperienced in dealing with law enforcement as possible. All of this matters, and all of it is by design; this is a campaign of terror that’s been coordinated.
A masked and armed man emerging from an unmarked vehicle and moving quickly to the door of your car with his arm outstretched to rip your door open and possibly grab you is terrifying. It’s the stuff of a waking nightmare for most law-abiding persons.
But above and beyond this, it’s a violation of both ICE standard operating procedures and the United States Constitution—which makes it even more understandable when a civilian, even a smart one, is shocked beyond measure by what’s happening to them.
The masked ICE officer who approached the driver’s-side door of the vehicle Renee Good was driving was supposed to contact local police for backup. But because it had been made clear to him by his bosses’ public statements that they see all Minnesota law enforcement and indeed many Minnesota leaders as clear enemies of Trump’s administration, the agent appears to have given no thought whatsoever to following standard operating procedures in this regard. Doing so would have been precisely the sign of weakness, adherence to norms, and concession to Democratic Party power bases in a blue state that Trump and his top officials have made clear is unacceptable in any of their agents.
By the same token, the Constitution required that this masked ICE officer approach Ms. Good’s vehicle professionally, calmly, and “reasonably” absent Ms. Good having directed violent behavior toward that officer or any other officer, which to our present knowledge she hadn’t and didn’t. Moreover, this masked ICE officer was empowered, as an ICE agent, only to approach her vehicle, ask her to roll down her window, and request that she move her vehicle—if doing so would have made it possible for ICE vehicles to pass by—and did not have authority to do anything more than this (as no contact by Ms. Good on the video qualifies as interfering in a federal operation in a way that would permit ICE agents to revert to generalized law enforcement activity in the absence of any coordination with local police officers).
Ironically, what video of the killing shows is that the armed-and-masked ICE agent who first approached Good’s car need hardly even have done this much—approached Good’s car and asked her to move it, that is—given that in the video we can clearly see Good waving the ICE vehicles past her vehicle on the street and before the armed ICE agent tries to execute a constitutional “seizure” by violently grabbing her driver’s-side door.
So in that moment, the agent had no reason to initiate a constitutional seizure at all.
Fortunately for investigators, we don’t need to imagine what was on the mind of the three ICE agents who surrounded Good’s vehicle, whether we are speaking of their masked (apparent) leader or the other two of them, as we can say almost for certain that their intention was to illegally arrest Good without any evident authority for doing so.
How do we know this? Good question.
First, the agent who ultimately killed Good was under an SOP requirement to not place himself in front of her vehicle, as doing so could endanger both him and her.
The only conceivable reason for an agent making the decision to violate his SOPs and do this anyway would be to curtail Good’s movement (by way of curtailing the moving of her vehicle) in a way that constituted an “arrest” under the famous Supreme Court case Rhode Island v. Innis (establishing that a government agent curtailing the freedom of a person to exit a situation us a touchstone marker of a seizure qualifying as arrest).
If we doubted that the killer’s present intention was to effectuate an illegal arrest, we can also look at the behavior of his (apparent) superior—inasmuch as the armed and masked man who first approached Good’s door used aggressive verbalization to order Good to “Get out of the car! Get out of the car! Get out of the fucking car!” (such verbalization, though much calmer and more professional than this, see below, is part of the Use-of-Force Continuum police SOPs use) and was reaching for her car door as he shouted this. This latter action means that he had already deemed her non-compliant to an order he was still in the process of giving her, and was escalating his use of force in response to that false determination, meaning that his reaching out his arm in the way he did signaled that he planned to physically detain Good in a way (known as empty-hand control in Use-of-Forcer SOPs) that would curtail her movement and her ability to exit the situation. It would, therefore, constitute an arrest. While we don’t know whether the agent intended to arrest Good’s freedom of movement by grabbing onto her vehicle, pulling her from it, or reaching into it and manually disabling it (or some combination of these three), that the masked and armed officer who emerged from an unmarked vehicle to rush at Good intended to initiate a constitutional seizure is clear.
As I write all this, keep in mind that I’m referring only to the information ICE agents would’ve had at the time regarding their remit, their authority, and their intentions.
They knew they were violating their own standard operating procedures in several ways.
They knew they were effectuating an illegal arrest.
They knew that they were terrifying a citizen who’d engaged in no violent conduct.
What I’m not saying here is that Renee Good knew any of this or had a basis to know any of this.
Nor that she was obligated to know any of this.
It’s the formal responsibility of law enforcement to act calmly and professionally—not civilians who may never have had prior police contact, and thus understand not one iota of how it’s supposed to work in real time.
In fact, from the attire and means of transportation and conduct of the men in front of Good, she had every reason to fear that they were not local law enforcement, were likely acting outside the bounds of any valid law enforcement activities, and for these reasons—and also by the manner of their approach—they posed a danger of imminent bodily injury to her and her passenger, possibly even an illegal seizure of her person by armed, faceless men without authority to make such a seizure. And in the context of Trump and his ICE agents having so far deported at least 80 U.S. citizens per major-media reports, the terror a citizen feels during ICE encounters is greatly heightened even beyond the terror a reasonable person would already feel in such a situation.
So while we can only guess at how terrified Renee Good was, we in fact can try with some confidence to retroactively imagine it. Her situation was objectively terrifying, and would terrify any reasonable person. Moreover, so much of what Trump and ICE are doing is unprecedented and intended to intimidate, such that no American can say they have experience with it unless they’ve previously lived abroad under a repressive authoritarian regime.
So what did Ms. Good do, having tried to wave the ICE vehicles past calmly, and been ignored? What did she do, as an armed and masked man without the legal authority to do so attempted to engage in general law enforcement activity of the most aggressive and unconstitutional character—stretching out his arm to seize her car door without her consent and without her having done anything to warrant such aggressive behavior?
She did what many of us might have. She tried to back up her car, turn her wheel, and exit the situation quickly and safely. In fact, had any of the ICE agents confronting her merely stopped in their tracks rather than trying to illegally arrest her, she would be alive right now, back at home with her six-year-old child. Very few of us would have heard her name.
Actually, what Renee Good did yesterday was exactly what—in theory—the three ICE agents wanted her to do, which was to move her vehicle so that it wasn’t sitting at an angle in the middle of the street (or just off the center of the street). In the video, the agents appear to act like they feel their drive-path forward is being blocked, though the video of the incident makes clear that it wasn’t, and so we would imagine they would be thrilled to see the person who was allegedly blocking their way waving them past her and then relenting in that (purported) course of action and clearing the road.
But what Good couldn’t have anticipated—what no one in law enforcement watching this video after the fact could have anticipated, for that matter—is that the man who was about to kill her had violated standard operating procedures again by stepping in front of her vehicle as she was looking at the man approaching her driver’s side door.
What Good couldn’t have anticipated—what no one in law enforcement watching this video after the fact could have anticipated—was that these ICE agents got out of their unmarked vehicles having already decided to arrest Good (illegally, as they lacked the authority to do so) rather than take “yes” for an answer and be (a) waved on by her, or (b) unencumbered by her after she had driven off, as she clearly took steps to try to do.
What Good couldn’t have anticipated—what no one in law enforcement watching this video after the fact could have anticipated—was that the ICE agent who was not in her line of sight as another masked agent approached her door had not only positioned himself (contra SOP) in front of her car but had begun pulling his weapon from his holster as she was trying to back up her car and exit the situation. Neither she nor anyone would have guessed this was happening, because ICE SOPs prohibit firing at a vehicle except in self-defense, so the ICE agent pulling his weapon as Good was backing her vehicle away from him couldn’t possibly have deemed his aggression warranted under that standard.
A law enforcement officer or federal agent of any kind drawing their weapon is one of the most serious things any government agent can do. So it’s something that is only supposed to be done under the most extraordinary circumstances. A car backing away from you is not such a circumstance. A civilian trying to evade your illegal arrest of them is not such a circumstance. In the latter case, you simply take the car’s license plate and issue a report, or—if you’re actually authorized to engage in generalized law enforcement activity (which ICE isn’t)—you initiate a pursuit and try to safely pull the vehicle over.
The very fact that ICE agents were desperate to seize Ms. Good in the street rather than taking her plate number and giving it to local law enforcement underscores that they knew they couldn’t engage in vehicular pursuit. In other words, ICE agents acted illegally and with premature violence on-scene because they so badly wanted to exert government violence on Good by physically restraining her movement that they chose to illegally force the issue rather than (a) call for local law enforcement, or (b) let that backup engage in a pursuit they well knew they could not themselves participate in.
What the viral video of her death shows is Good backing up her vehicle with the intention of exiting the scene, as evidenced by her turned wheel. Had she in that moment intended to harm anyone with her vehicle, there would have been no reason for her to back up at all—she could have just begun driving her car in such a way that it would hit someone from law enforcement—and she wouldn’t have turned her wheel in a way that directed her car out of the path of the three ICE agents surrounding her.
But as Good put her car in drive; as she turned her wheel as far as she could to the right, which was exactly what was necessary to do to exit the situation, and something she did slowly enough that the ICE officer who had stepped in front of her vehicle without her knowledge in an attempt to arrest her had ample time to get out of the way (from a position he should never have been in in the first place); that agent began raising up his gun to either (a) stop her via threat (i.e., a government seizure achieved by upping his use of force significantly with the aiming of a deadly weapon at her), or (b) actually shoot and kill her (as law enforcement agents aren’t, contrary to common misperceptions, trained to shoot-to-injure; they’re taught to aim for center of body mass if possible, or any exposed and unprotected area if not, in order to put someone down from a shoot-to-kill fighting posture).
If in fact this agent was slightly slow in getting out of the way of Good’s vehicle—if, that is, his body was in any way touched by Good’s vehicle as it sought to exit the situation with a turned wheel that was going to take it away from him—it’s because he decided to take the time to pull his sidearm unnecessarily and inappropriately, and in doing so slowed his ability to get himself out of the situation he’d put himself (and Good) in.
What we see next in the video is the killer firing once into the lefthand corner of the vehicle’s windshield as he’s finally getting out of the way of the vehicle, and then twice more directly into—it’s believed—the head or upper body of Renee Good through her open driver-side window. (Remember, the fact of that open window only underscores that Good was communicating with officers rather than having made some notional decision to harm them; we see this in the video, for instance, in her waving them past her and her vehicle, something she does by putting her arm out that open window.)
It’s possible that Good was already dead by the time the killer’s third shot hit her, but in any case she certainly had no ability to maneuver her vehicle at that point. So the video ends with the vehicle traveling down the street a short way and striking another car.
Note that it’s the movement of Good’s vehicle after she was apparently dead or semi-conscious or unconscious that Trump and his top officials at DHS—as well as his top mega-donor, Elon Musk—showed to the country on social media in an effort to try to convince low-information voters that it was this final horrific 5% of the incident that was the moment in which Renee Good was navigating her vehicle in a dangerous way (the central claim of their ex post disinformation about her and her death).
In fact, Good wasn’t navigating her vehicle at all at that point—as surely everyone who showed this clip of the end of the incident to America as though it were the beginning of it either knew or should have known before doing so.
We know that the killer wasn’t injured seriously—and likely not at all—because he ran down the street after Good’s vehicle, then slowly walked back up the street afterward in a video taken by a bystander that has since gone viral as well. In the latter video, he is seen looking for an escape vehicle to get him out of the street and possibly out of the state; he has, by then, clearly processed that he has just killed someone.
He’s even seen pulling his mask further up his face to ensure that he’s not identified.
While additional investigation and more video reviews are needed, on the face of it this situation presents what in most states would be deemed Second-Degree Murder—the type of charge employed by prosecutors when a person has so little regard for human life that they manifest an indifference to whether someone lives or dies while wielding a deadly weapon (for this reason, Second-Degree Murder is called a “black-hearted” crime in British common law, as someone who commits it is deemed not to have planned a homicide but simply had so little regard for human life that they were always a risk to do something like this).
If prosecutors determined, instead, that the killer and his fellow agents were acting out of transient anger at being (allegedly) blocked in the performance of their duty, and deemed that anger to be provoked and justifiable—if not in what it finally produced—a Voluntary Manslaughter charge might be the one that best fits this case, instead.
But either charge could lead to a prison bid measured in years rather than months.
It’s no secret that ICE no longer has any serious recruiting standards, isn’t properly training its recruits, is accepting in large numbers Trump supporters who hate their fellow blue-state/blue-city citizens and don’t know how to be law enforcement agents or care to learn. It’s no secret that all this is happening by the explicit design of Donald Trump, Stephen Miller, Kristi Noem, Corey Lewandowski, and other officials at the White House and in DHS. These officials want America’s federal executive branch to experience a schism with local police departments over the unwillingness of the latter to become subjects of the former’s boss—Trump—which situation is, again, a violation of the basic principles of federalism that we have told for decades MAGAs and their conservative predecessors (for instance, The Tea Party) are devoutly passionate about.
This is another way of saying that decisions were made premeditatedly by Trump and Noem and others that they knew or should have known would lead to civilian deaths.
And that it is precisely this civil and possibly even criminal liability that causes people like Trump and Noem to immediately issue statements, after a horrifying killing-cum-execution like this one, slandering the victim as a “domestic terrorist,” lying about the contents of a video tens of millions of Americans have now seen, misstating key legal principles that anyone who’s even watched a police procedural is familiar with, and in general misframing themselves and their agents as victims of exactly the civil uprising many of us now expect Trump will shortly use as a pretext for declaring martial law.
Absent significant new information, the ICE agent in question should of course be suspended and then fired, and thereafter indicted and convicted and incarcerated.
The question really is what period of incarceration will be appropriate.
Sadly, it is unlikely that this go thjis way
If past is precedent, the killer is likely to be smuggled out of the state by his bosses; have every aspect of his identity that can be hidden, hidden; be preemptively pardoned by Trump (whether formally or in sub rosa fashion); and refuse to return to Minnesota for questioning or any legal proceeding. He may even be kept on the job at full pay or be allowed to continue his field work uninterrupted. No one should expect that this saga is over, as in the best-case scenario it ends in an arrest warrant for this ICE agent and in the worst mass civil unrest over him facing no consequences of any kind at all.
By the same token, absent significant new information, it should be clear to all that the current Trumpist mass deportation scheme has been deliberately structured to violate the Constitution and nearly all campaign promises made by Donald Trump in 2024, and that the former point by itself presents sufficient basis to impeach not only DHS head Kristi Noem but Trump himself. I frankly think many would go further and suggest that Noem and Trump bear criminal liability for orchestrating a nationwide army of armed, masked, insignia-less thugs who lack the training or temperament or understanding of American law or law enforcement to do anything but, with alarming frequency, murder American citizens who have done nothing wrong.