United States Homeland Security Secretary Kristi Noem has described the actions of Renee Nicole Good, a Minneapolis woman killed by an Immigration and Customs Enforcement (ICE) officer on Wednesday, as “domestic terrorism”.

Noem said Good refused to obey orders to get out of her car, “weaponise[d] her vehicle” and “attempted to run” over an officer. Minnesota officials disputed Noem’s account, citing videos showing Good trying to drive away.

Minnesota Attorney General Keith Ellison, a member of the state’s Democratic-Farmer-Labor Party, said on Thursday on the CNN news channel that Noem’s statement is “an abuse of the term” “domestic terrorism”.

President Donald Trump’s administration has turned to the phrase in recent months, including in an October immigration enforcement-related shooting.

In September, the administration issued a memo calling on law enforcement to prioritise threats including “violent efforts to shut down immigration enforcement”, saying “domestic terrorists” were using violence to advance “extreme views in favour of mass migration and open borders”. Experts said it violates free speech laws.

Good, a mother of three and a poet, lived in the Minneapolis neighbourhood where she was fatally shot. She was a US citizen and had no criminal background, The Associated Press news agency reported. Good’s ex-husband told AP that she wasn’t an activist and he hadn’t known her to participate in protests. Good had dropped off her 6-year-old son at school and was driving home when she encountered ICE.

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The Trump administration has ramped up Minneapolis immigration enforcement in recent weeks after news reports about allegations of daycare funding fraud 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, citing a specific section of the US Code, defines “domestic terrorism” as acts dangerous to human life that violate federal or state criminal laws and appear intended to intimidate or coerce civilians; influence government policy by intimidation or coercion; or affect the conduct of a government by mass destruction, assassination or kidnapping.

The Department of Homeland Security (DHS) uses a similar definition, citing a different statute that defines “domestic terrorism” as dangerous to human life or potentially destructive of 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 an individual with domestic terrorism which sometimes makes it difficult (and occasionally controversial) to formally characterise someone as a domestic terrorist.”

In 2022, former FBI agent Michael German, then a fellow with New York University Law School’s Brennan Center for Justice, told PolitiFact that 51 federal statutes apply to “domestic terrorism”.

“I think there is and always has been confusion between rhetoric and the law in regard to terrorism,” German told PolitiFact after the Minneapolis shooting. “There is no law that authorises the US government to designate any group or individual in the US as a ‘domestic terrorist’.”

The federal government periodically revises how it describes threats. For example, in 2025, federal officials sometimes used the term “nihilistic violent extremists” to describe perpetrators who don’t subscribe to one ideology but appear to be motivated by a desire to, as one expert put it, “gamify” real-life violence. Experts told PolitiFact that the term is valid but cautioned against its overuse or citing it to obscure other ideological motivations, such as white supremacy.

The Trump administration has broadened the ‘domestic terrorism’ label

The DHS rhetoric around Good’s fatal shooting is similar to another immigration enforcement-related shooting in October. During DHS’s months-long immigration crackdown in Chicago called “Operation Midway Blitz”, a Border Patrol agent shot US citizen Marimar Martinez five times.

A DHS news release described Martinez as a “domestic terrorist” and accused her of ramming her vehicle into the Border Patrol agent’s car, carrying a semiautomatic weapon and having a “history of doxxing federal agents”.

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A federal judge granted a motion from prosecutors to dismiss federal charges against Martinez in November.

“Ultimately, there was a determination when everything was evaluated that there were serious questions about the officers’ narratives,” legal analyst Joey Jackson told CNN.

The government’s use of the term goes beyond immigration and the DHS.

After conservative activist Charlie Kirk’s murder, Trump issued a September 25 memo ordering the attorney general to expand “domestic terrorism” priorities to include “politically motivated terrorist acts such as organised doxing campaigns, swatting, rioting, looting, trespass, assault, destruction of property, threats of violence, and civil disorder”.

Trump signed an executive order a few days before designating antifa, a broad, loosely affiliated coalition of left-wing activists, as a “domestic terrorist” organisation.

US Attorney General Pam Bondi told federal prosecutors and law enforcement agencies to compile a list of groups “engaged in acts that may constitute domestic terrorism”.

Legal experts have raised alarms about the memo’s potential infringements on the First Amendment.

“Both the order and the memo are ungrounded in fact and law,” Faiza Patel, the director of liberty and national security at the Brennan Center for Justice, wrote. “Acting on them would violate free speech rights, potentially threatening any person or group holding any one of a broad array of disfavored views with investigation and prosecution.”

Experts have also pointed to the memo’s focus on left-wing violence. It does not mention the politically motivated assassination of Minnesota state Representative Melissa Hortman, a member of the state’s Democratic-Farmer-Labor Party, months before.

“When a policy directive targets one ideological family and leaves others to the footnotes, it sheds any pretense of neutrality,” Thomas E Brzozowski, former Department of Justice counsel for domestic terrorism, wrote on December 12.

Experts raise questions about Noem’s ‘domestic terrorism’ label

Information is still surfacing about what transpired before Good was fatally shot. However, frame-by-frame analyses of video footage by The New York Times and The Washington Post found Good’s vehicle moved towards an ICE agent, but the agent was able to move out of the way and fire at least two of the three shots from his gun from the side of the car as Good veered away.

Brzozowski told PolitiFact that because Good was trying to drive away, to “characterise that as domestic terrorism, I think, is a stretch.”

However, he said the larger concern is that Noem is using the “domestic terrorism” term absent any actual findings before an investigation.

“Essentially within hours of the incident occurring, labelling this activity as domestic terrorism, what that does is effectively strip domestic terrorism of its significance,” he said, calling it a “blatantly partisan effort to label it as domestic terrorism”.

“Now what is domestic terrorism? Whatever the DHS secretary says it is? She can characterise anything she wants as domestic terrorism. She is doing so without any facts to go on.”

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Shirin Sinnar, a Stanford University Law School professor, told PolitiFact: “While intentionally ramming a vehicle for a political purpose could amount to terrorism in a different context, the videos of the Minneapolis incident appear to show a woman attempting to drive away from ICE officers, not hit them. Here, the administration’s calling her a domestic terrorist is simply an attempt to malign a protester and justify her killing by an ICE officer.”

German told PolitiFact there isn’t any public evidence to suggest that Good was “engaging in conduct that could have been prosecuted under the terrorism chapter of the US Code”.

“So a government official calling her a domestic terrorist isn’t supported in the law and is entirely pejorative and prejudicial.”