In 2025, DHS smashed the window of a passenger van in which the Petitioner--a mother and farmworker and resident of Oregon--was riding in to work and arrested her  to fullfil their quotas. That is, DHS arrested and detained Petitioner not for anything particular about her; but, rather, DHS had a detention quota to meet. So, in spite of her years and years of compliance with the conditions of release and that DHS had entirely ceased its action to remove her from the United States, she was taken from Oregon and her family and transported rapidly to the immigration detention center in Tacoma, Washington. She is suing because her detention-by-quota is unconstitutional.