KRISTI NOEM
Secretary of Homeland Security
Sworn in January 25, 2025 — Fired by President Trump, March 5, 2026
TERMINATED
All individuals listed deny wrongdoing. These charge sheets represent reported conduct mapped to applicable federal statutes for the purposes of political commentary and satire, based on news reporting, court filings, inspector general reports, and congressional testimony from 2025–2026. No charges have been filed against any individual listed. This document does not constitute legal advice or a legal determination of guilt. The President of the United States has not been charged with any offenses listed herein; under longstanding Department of Justice policy, a sitting president cannot be indicted while in office.
COUNT 1 — OBSTRUCTION OF CONGRESSIONAL OVERSIGHT
2 U.S.C. § 192 — Refusal to Comply with Congressional Authority
On May 13, 2025, Noem implemented a policy requiring Members of Congress to provide a minimum of seven calendar days' advance notice before visiting DHS detention facilities. This directly violated the fiscal year 2024 DHS Appropriations Act (Public Law No. 118–47), which explicitly provides that it may not "be construed to require a Member of Congress to provide prior notice of the intent to enter a Department of Homeland Security facility." In August 2025, a Member of Congress arriving at the Northwest ICE Processing Center in Tacoma, Washington was denied entry without explanation. A House resolution (H.Res.996) was introduced impeaching Noem specifically on this count.
COUNT 2 — DEPRIVATION OF RIGHTS UNDER COLOR OF LAW
18 U.S.C. § 242 — Deprivation of Rights
A federal judge in Chicago found in November 2025 that DHS under Noem's direction "regularly and systemically targeted non-violent civilians and members of the press while they are exercising their First Amendment rights," and documented that Noem had instructed federal agents to "go hard" and "hammer" individuals based on "the way they are talking, speaking, who they're affiliated with." In January 2026, federal agents shot and killed two American citizens — Renée Good and Alex Pretti — during enforcement operations in Minnesota. Noem publicly defended the killings before any investigation had been conducted. A federal judge in Portland separately documented a months-long "escalating" pattern of DHS agents attacking protesters, observers, and members of the press with tear gas, pepper balls, and projectiles.
- New York Times: "Judge Finds DHS 'Systematically Targeted' Civilians Exercising Free Speech" (November 2025)
- Washington Post: "Federal Agents Kill Two American Citizens During Minnesota Enforcement Operations" (January 2026)
- OPB: "Portland Judge Documents Escalating Pattern of DHS Attacks on Protesters and Press" (December 2025)
COUNT 3 — CRIMINAL CONTEMPT OF COURT
18 U.S.C. § 401 — Contempt of Court
The chief federal district judge in Minnesota, Patrick Schiltz, found that "ICE has likely violated more court orders in January 2026 than some federal agencies have violated in their entire existence," documenting at minimum 97 court orders in 66 cases that ICE violated under Noem's tenure, with an additional 113 violations subsequently identified. Federal courts in multiple states issued similar findings. Noem failed to take corrective action following direct judicial admonition and testified before Congress that DHS had not violated any court orders — statements that Senate and House Judiciary Committee ranking members subsequently referred to the DOJ as potential perjury.
COUNT 4 — IMPOUNDMENT OF APPROPRIATED FUNDS
2 U.S.C. §§ 684–685 — Impoundment Control Act
A Government Accountability Office report (B–337204.2) found that FEMA, under Noem's supervision, withheld funds obligated by Congress for the Emergency Food and Shelter Program and the Shelter and Services Program in violation of the Impoundment Control Act. When the GAO contacted Secretary Noem's office for additional information, her team refused to respond.
COUNT 5 — THEFT / MISUSE OF PUBLIC FUNDS
18 U.S.C. § 666 — Theft or Embezzlement from Programs Receiving Federal Funds
Noem directed a $220 million taxpayer-funded DHS television advertising campaign to allies and contractors connected to her personally, bypassing standard federal procurement processes. The DHS Inspector General — a Trump appointee — told lawmakers that at least 11 of his investigations had been "systematically obstructed" by Noem's office, including at least one criminal probe. The obstruction of the IG's work reached a breaking point when DHS classified a report from the Inspector General's office, preventing its public release.
- New York Times: "Noem Directed $220 Million Ad Campaign to Allies, Bypassing Procurement Rules" (February 2026)
- Washington Post: "DHS Inspector General: 11 Investigations 'Systematically Obstructed' by Noem's Office" (February 2026)
- ProPublica: "DHS Classified an Inspector General Report to Prevent Its Public Release" (February 2026)
COUNT 6 — PERJURY / FALSE STATEMENTS TO CONGRESS
18 U.S.C. § 1621 — Perjury; 18 U.S.C. § 1001 — False Statements
Following her testimony before the Senate Judiciary Committee (March 3, 2026) and the House Judiciary Committee (March 4, 2026), the ranking members of both committees — Sen. Dick Durbin and Rep. Jamie Raskin — submitted a formal criminal referral to Attorney General Bondi, alleging that Noem falsely stated on multiple occasions that DHS had not violated any court orders, made false claims about the bidding process for the $220 million ad campaign, and made false claims about the detention of U.S. citizens. DHS denied all allegations. Trump fired Noem the same day the House hearing concluded.
- C-SPAN: Senate Judiciary Committee — Noem testimony (March 3, 2026)
- C-SPAN: House Judiciary Committee — Noem testimony (March 4, 2026)
- New York Times: "Durbin and Raskin Refer Noem for Perjury; Trump Fires Her the Same Day" (March 5, 2026)
- Washington Post: "Trump Fires Homeland Security Secretary Noem After Combative Congressional Hearings" (March 5, 2026)