"The Snapshot" (THE COMMON ILLS):
Wednesday, January 21, 2026. Chump's tariff lies are getting exposed more and more often, the gestapo force that is ICE continues to terrorize communities, and much more.
For anyone not getting the con that Chump played on America, Joseph Zeballos-Roig (QUARTZ) walks you through:
Who's picking up the tab for President Donald Trump's tariffs? Americans, overwhelmingly. A new study released Monday by a group of researchers at the German-based Kiel Institute for the World Economy found that U.S. consumers paid the largest chunk of the tariffs: 96%, to be specific.
"Tariffs are framed as a tool to extract concessions from trading partners while generating revenue for the U.S. government — at no cost to American households," the analysis said. "Our research shows the opposite: American importers and consumers bear nearly all the cost."
Trump administration officials have repeatedly claimed that foreign countries and companies are the ones paying the tariffs. The president has cast them as a critical tool to negotiate new trade agreements and uphold national security. Most GOP lawmakers reluctantly support that argument, enabling Trump to expand the executive branch's authority to levy tariffs. Historically, that's been the purview of Congress.
There's a growing body of research contradicting claims that foreign firms and nations bear the brunt of tariffs, particularly in the case of the president's barrage of import taxes put in place over the past year.
The research comes as Trump threatens to impose import taxes on European nations over his desire to seize Greenland for the United States. The president has coupled tariff threats with bombastic, menacing rhetoric in an attempt to accomplish that goal, blowing up an earlier interim trade agreement with the European Union in the process.
Michael Hiltzik (LOS ANGELES TIMES) notes, "In 2025, Kiel wrote, the $200 billion that the U.S. treasury collected from Trump’s tariffs was tantamount to a $200-billion consumption tax on Americans. Staying with the economy for a moment more, Chump is a liar. In fact, he's the liar supreme. Max Zahn (ABC NEWS) notes:
KERN COUNTY, CA — Today, U.S. Senators Alex Padilla, Ranking Member of the Senate Judiciary Immigration Subcommittee, and Adam Schiff, a member of the Senate Judiciary Committee, conducted an oversight visit to the largest detention center in California, located in California City, to learn firsthand of the concerns surrounding the condition of detained individuals at this facility amid the Trump Administration’s mass detention and deportation campaign. One year into President Trump’s disastrous, anti-immigrant presidency, the Senators exercised their Congressional oversight role through a briefing and tour of the facility before meeting with dozens of Californians and other detained individuals, many with no criminal record, whom Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) have swept up indiscriminately.
The oversight visit comes as the number of immigrants detained by ICE swells to nearly 73,000 — more than ever before in U.S. history. After 32 people died in ICE custody in 2025, the deadliest year since 2005, at least six individuals have already died in their custody this year.
After ICE began transferring people to the CoreCivic-managed facility in late August, they have rapidly expanded the facility toward their goal of filling all 2,560 beds, raising significant concerns about ICE and CoreCivic’s ability to maintain adequate conditions for the people detained there. ICE officers informed the Senators today that the facility now holds 1,450 detained individuals.
With Congress set to consider legislation to further increase ICE funding and detention beds, the Senators pulled back the curtain on the inhumane conditions detained individuals at California City are facing. The Senators investigated reports of unsanitary and unsafe facility conditions, inadequate medical and mental health care, insufficient access to legal counsel, a severe lack of accommodations for people with disabilities, and the unnecessary use of solitary confinement.
“One year into Donald Trump’s campaign of terror against immigrant communities, we must hold this Administration accountable for its cruel and indiscriminate mass deportation agenda,” said Senator Padilla. “We saw firsthand today at California’s largest detention center the inhumane conditions that detained individuals are facing, violating basic standards for access to health care, food, water, and legal counsel. ICE and CBP continue to detain immigrants with no criminal record, all while wasting billions in taxpayer funds and doing little to increase public safety. With more and more people dying in ICE custody as detentions reach record levels, I won’t stop fighting to ensure basic protections for detained individuals and end the egregious abuses of power by this out-of-control Administration.”
“I’ve been aghast at what we’re seeing around the country and in California, with indiscriminate immigration raids and with the brutality that’s being used against people who have no criminal record. And one year in, things may just get worse, with the President threatening to invoke the Insurrection Act, further militarize the streets and use the military against their own people. Much of the trauma people are experiencing in our communities is out in the open, often captured on video. The pain people experience after their arrest is hidden from view, and that is why we are here today. To conduct necessary oversight, and see firsthand what the conditions are like, and to make sure that people are treated humanely and have their rights observed,” said Senator Schiff.
California groups previously unveiled major issues with conditions at the California City Detention Facility. Disability Rights California (DRC), the largest disability rights organization in the nation, found that the facility “fails to meet people’s basic needs,” lacks “access to critical medical” care, and “employs staff who harass” detained people, while subjecting dozens of individuals to solitary confinement. After California Department of Justice staff visited the facility in November 2025, Attorney General Rob Bonta sounded the alarm that the rapid scaling up of detentions shortly after the facility reopened did not provide CoreCivic enough time to ensure that the facility was adequately prepared to accommodate detained individuals.
The California City facility operates under less stringent and protective standards and still has not been inspected by the Department of Homeland Security.
Senator Padilla has been a leading voice in opposition to President Trump’s cruel and indiscriminate mass deportation agenda and denial of basic services for detained individuals. Last year, Padilla introduced the Access to Counsel Act to ensure that U.S. citizens, green card holders, and other individuals with legal status can consult with an attorney, relative, or other interested parties to seek assistance if they are detained by CBP for more than an hour at ports of entry, including airports. Padilla and Schiff also introduced the Restoring Access to Detainees Act, a bill to ensure the Department of Homeland Security allows detained noncitizens to contact legal counsel and their families. Last July, Padilla joined a Senate Judiciary Immigration Subcommittee hearing to set the record straight on President Trump and Stephen Miller’s cruel mass deportation campaign, blasting the Administration for intentionally stoking fear and scapegoating immigrants.
Video of Padilla and Schiff’s remarks following the briefing and tour can be watched here and downloaded here. Padilla’s remarks in Spanish are available here.
Additional photos from the event are available here.
###
Instead, as NPR's Martin Kaste observed on January 9th, ALL THINGS CONSIDERED, "And I think what's not normal here is the way the federal officials have been publicly passing judgment on a case that's still being investigated. For instance, just today, the vice president posted a video that appears to have come from a device being held by the agent who shot Renee Good on Wednesday. It shows Good smiling and saying she's not mad at the officer. But Vance called the video evidence that the officer was in danger. So there seems to be a real disconnect right now on the basic level of what the evidence means." Fat and little Vice president JD Vance is a professional troll but his efforts this time are especially outrageous. John Grosso (NATIONAL CATHOLIC REPORTER) observed:
Yesterday (Jan. 7), 37-year-old Renee Good was shot and killed in a residential Minneapolis neighborhood by an Immigration and Customs Enforcement officer. Good was a mother of three and an U.S. citizen.
Today, JD Vance has taken to social media to justify the shooting and blame Good for her own death.
Though the full circumstances of the situation are still coming to light, widely available video evidence shows the horrific moments before, during and after shots were fired into Good's car. Videos of the shooting and the ensuing aftermath are graphic and disturbing. After Good was shot, her car accelerates, slamming into another car and a pole. In one video, a person can be heard identifying themselves as a physician and offering to help only to be angrily denied by an unidentified ICE agent saying: "I don't care."
The Trump administration was quick to demonize Good. Within hours of the event and before a formal investigation could even be launched, Homeland Security Director Kristi Noem labeled Good's actions as an "act of domestic terrorism." President Donald Trump on Jan. 7 labeled her as "disorderly, obstructing and resisting, who then violently, willfully, and viciously ran over the ICE Officer." Trump went on to say that the ICE officer was lucky to be alive and "is now recovering in the hospital."
[. . .]
As a Catholic, Vance knows better than to peddle this brand of gaslighting and agitation. Vance knows that, by virtue of her humanity, Good was endowed with inherent dignity, made in the image and likeness of God. Vance knows that only God can take life. Vance knows that protesting, fleeing or even interfering in an ICE investigation (which there is no evidence that Good did) does not carry a death sentence. Vance knows that lying and killing are sins.
Vance knows. He doesn't care. Vance’s twisted and wrongheaded view of Christianity has been repudiated by two popes. His Catholicism seems to be little more than a political prop, a tool only for his career ambitions and desire for power.
The vice president's comments justifying the death of Renee Good are a moral stain on the collective witness of our Catholic faith. His repeated attempts to blame Good for her own death are fundamentally incompatible with the Gospel. Our only recourse is to pray for his conversion of heart.
Mike's response to Vance's outrageous lies, "As a Catholic, I'm sick of this little bitch distorting my religion. He needs to be excommunicated. I'm not joking. He is presenting as a Catholic -- he's been a Catholic for about five minutes -- and he is distorting our beliefs and our teaching. Two popes have repudiated him -- Pope Francis and now Pope Leo. Excommunicate Vance, don't let him speak for the Church or pose as a Catholic. Whatever crap he was raised before distorted his damn mind. We cannot allow him to pervert the Catholic faith."
At AMERICA: THE JESUIT REVIEW, James T. Keane writes:
After Renee Nicole Good was shot and killed in her minivan by an Immigration and Customs Enforcement officer in Minneapolis on Jan. 7, Vice President JD Vance called her murder “a tragedy of her own making” and claimed that Ms. Good, a community activist and a mother of three, was “part of a broader left-wing network to attack, to dox, to assault and to make it impossible for our ICE officers to do their job.”
Mr. Vance claimed further that Ms. Good “viciously ran over the ICE officer” who shot and killed her, an assertion contradicted by video evidence taken from multiple angles.
Why the obvious lie? Because, similar to Ms. Kirkpatrick and Mr. Haig, Mr. Vance recognizes the potential for this atrocity to turn American public opinion against President Trump’s brutal campaign against undocumented immigrants, particularly because Ms. Good is an American citizen, was apparently denied medical assistance by ICE agents after the shooting and, according to the video evidence, posed no real threat to the shooter. Not even the most fervent supporter of the arrest and deportation of undocumented migrants, one assumes, would defend such Gestapo-like tactics.
The answer? Blame Ms. Good for her own murder.
Mr. Vance’s boss, President Trump, has engaged in further deceit and hyperbole in support of that same goal, claiming that Ms. Good “violently, willfully, and viciously ran over the ICE officer, who seems to have shot her in self-defense.” She made for an easy culprit for a man desperate to justify ICE’s actions. After all, she was already dead.
The murder of the churchwomen in El Salvador in 1980 was not an isolated incident; they shared the fate of tens of thousands of other Salvadorans, including Rutilio Grande, S.J., St. Oscar Romero, and the six Jesuits and two laywomen who were murdered by the Salvadoran military in 1989 in San Salvador. Eventually, the overwhelming evidence of these murders became too much for American politicians to justify, and U.S. funding for the Salvadoran military government dried up. It just became impossible to believe the lie anymore.
On the 40th anniversary of the martyrdom of the churchwomen of El Salvador, Cardinal Michael Czerny, S.J., preached at a memorial Mass in Rome on the impact of their witness. “Theirs, mysteriously but without doubt, is the triumph because vigorous, courageous acts of solidarity and compassion persist in dreadful, risky conditions,” he said. “Brutal claims failed and fail to stop the evangelizing.”
Let us hope the same will happen in Minneapolis. Nothing can bring Renee Good back; her 6-year-old son is without his mother now, her partner a widow. The masked man who killed her simply drove away. Nor is her death an isolated incident: All over the country, we hear and see more and more examples of violent attacks by masked ICE agents who seem to face no accountability for their crimes. And we hear the brutal claims used after the fact to justify them.
How long before it simply becomes impossible to believe the lie anymore?
Winding down, Senator Sheldon Whitehouse's office issued the following:
Chairman Cruz letter and subcommittee hearing are one vector of a coordinated MAGA intimidation campaign against the federal judiciary
Washington, D.C. – Senator Sheldon Whitehouse (D-RI), Ranking Member of the Senate Judiciary Courts Subcommittee, has alerted House Speaker Mike Johnson (R-LA) to inaccuracies in a January 7 letter he received from Senate Judiciary Courts Subcommittee Chairman Ted Cruz (R-TX) regarding the potential impeachment of Chief Judge James Boasberg. Chairman Cruz also held a hearing that day amplifying calls for Chief Judge Boasberg’s impeachment. Whitehouse clarified the facts in a letter issued to Speaker Johnson on Thursday.
Chief Judge Boasberg, a distinguished federal district court judge in the District of Columbia, has found the Trump administration in violation of federal law in several high-profile cases and has been the target of a barrage of threats by the MAGA movement and the Trump administration. These threats appear intended to intimidate Chief Judge Boasberg and prevent him from examining potential contempt of court by the MAGA Department of Justice and are part of a larger coordinated campaign of threats against federal judges who have ruled against President Trump.
“Since President Trump took office, federal judges and their families have been subjected to a surge of threats, harassment, and intimidation. The Marshals Service is responding to unprecedented risk levels, and security appropriations have had to be increased. The pattern is clear: judges rule against the Administration; the President or his allies attack and spread misinformation; judges and their families receive threats, ‘swatting’ attempts, and threatening stunts like pizzas in the name of a federal judge’s murdered son. DOJ has repeatedly refused to assure us that they are investigating the pattern of threats for possible orchestration. Baseless calls for impeachment in this threat environment only add to the dangers facing these judges and their loved ones,” wrote Whitehouse in the letter.
Whitehouse spotlighted six inaccuracies in Chairman Cruz’s letter about Chief Judge Boasberg’s role in ruling on non-disclosure applications regarding subpoenas issued by Jack Smith as part of Smith’s investigation into President Trump’s attempts to overturn the 2020 election:
- Chief Judge Boasberg did not “secretly approv[e] and seal” grand jury subpoenas for senators’ phone records in connection with Jack Smith’s investigation into attempts to overturn the 2020 election. Jack Smith issued those subpoenas, which did not require judicial approval.
- Special Counsel Jack Smith’s subpoenas did not seek senators’ “text messages, voicemails, and geolocation data.” Only telephone toll records, which merely indicate that a call took place, were collected.
- Chief Judge Boasberg did not “target” Republican senators. Jack Smith, not Chief Judge Boasberg, issued those subpoenas because President Trump and his associates tried to call those members of Congress to further their scheme to overturn the 2020 election. Moreover, when he issued the non-disclosure orders, Chief Judge Boasberg did not know to whom the subpoenaed phone numbers belonged.
- Chief Judge Boasberg did not “disregard” federal law protecting senators’ phone records. Chief Judge Boasberg could not have considered that law if he did not know senators’ records were at issue, and, under DOJ policy at the time, Jack Smith did not disclose that information.
- Chief Judge Boasberg did not presume that “sitting United States Senators would destroy evidence or intimidate witnesses.” The non-disclosure orders do not say that, and Chief Judge Boasberg could not presume that if he did not know senators’ phone numbers were involved.
- Chief Judge Boasberg did not act without basis approving the non-disclosure orders. President Trump and his co-conspirators had a pattern and practice of trying to tamper with evidence, intimidate witnesses, and interfere with Jack Smith’s investigations.
Senator Whitehouse also sent a letter last week urging Attorney General Pam Bondi to disclose the result of the Department of Justice’s bogus disciplinary complaint against Chief Judge Boasberg, part of a scheme to harass him as he investigates the Department’s misconduct.
In November, Whitehouse and Senators Richard Blumenthal (D-CT) and Adam Schiff (D-CA) submitted FOIA requests to the Department of Justice demanding records related to the delay of Chief Boasberg’s contempt of court proceedings against the Department, as well as the online orchestration of threats against federal judges who have ruled against the Trump administration.
The text of the letter to Speaker Johnson is below and a PDF is available here.
January 15, 2026
The Honorable Mike Johnson
Speaker of the House of Representatives
United States House of Representatives
Washington, D.C. 20515
Dear Speaker Johnson:
I write to clarify inaccuracies in a January 7, 2026, letter Senator Cruz sent you regarding impeachment of Chief Judge James Boasberg. The House deserves accurate information before proceeding to such a measure.[1]
This letter, and a related subcommittee hearing, are part of a campaign of attacks on Chief Judge Boasberg. Why? Chief Judge Boasberg stopped DOJ’s illegal deportations and has inquired into possible contempt for defying that order.[2] He sentenced January 6 rioters.[3] He exposed FBI Director Patel’s lies to the Senate Judiciary Committee.[4] He presided over Jack Smith’s grand jury investigation into President Trump’s 2020 election crimes.[5] And he is the likely target of then-Principal Associate Deputy Attorney General Emil Bove’s threat to tell courts “fuck you.”[6]
So President Trump has called Chief Judge Boasberg a “Radical Left Lunatic Judge”;[7] DOJ has submitted a seemingly meritless ethics complaint;[8] Senate Republicans have called for his “suspension”;[9]House Republicans have tried to defund his chamber;[10] and the Deputy Attorney General has called for “war.”[11] The judge is consequently the subject of constant threats, and requires augmented security.
That brings us to Senator Cruz’s calls for impeachment, as to which I offer the following clarifications.
First, the Cruz letter says Chief Judge Boasberg committed impeachable conduct by “secretly approving and sealing” grand jury subpoenas for senators’ phone records in connection with Jack Smith’s investigation into attempts to overturn the 2020 election.[12] As the Administrative Office of U.S. Courts (A.O.) reminded senators in a recent letter, federal prosecutors issue grand jury subpoenas “without approval or sign-off by any judge” and file them under seal as a matter of law.[13] Smith confirmed as much under oath to the House Judiciary Committee.[14]
Chief Boasberg did approve applications to temporarily prohibit subpoena recipients from disclosing those subpoenas. In approving those “non-disclosure orders” (NDOs), Chief Judge Boasberg likely never saw the subpoenas. The recipients did not challenge the subpoenas before Chief Judge Boasberg, and, as the A.O. pointed out, NDO applications “typically do not attach the related subpoena,” so he would have had no reason to see them.[15]
Second, the Cruz letter says Jack Smith’s subpoenas sought senators’ “text messages, voicemails, and geolocation data.”[16] As Senate Judiciary Chairman Grassley admitted: Smith’s subpoenas were for telephone “toll records” showing “when and to whom a call is made, as well as the duration and general location of the call”—“not . . . the content of the call.”[17] No content of any kind was sought or collected. Jack Smith confirmed that too.[18]
Third, the Cruz letter accuses Chief Judge Boasberg of “targeting” Republican senators.[19] Jack Smith—not Chief Judge Boasberg—issued those subpoenas because “President Trump and his associates tried to call Members of Congress in furtherance of their criminal scheme.”[20] As Smith testified, “I didn’t choose those Members; President Trump did.”[21]
To the extent this claim relates to the approval of the NDOs, under the prevailing practice of the court and the Department at the time, the judge would not know to whom the subpoenaed phone numbers belonged. That was the same practice when President Trump’s DOJ subpoenaed toll records of members of Congress in the first term.[22]
Fourth, Senator Cruz says Chief Judge Boasberg “disregarded” federal law protecting senators’ phone records.[23] Chief Judge Boasberg likely did not know and had no reason to suspect that senators’ phone records were at issue. Judges usually do not know whose toll records are at issue in NDOs because DOJ historically has not included that information in NDO applications. These applications include only a “signifier — e.g., a phone number.”[24] That practice did not change until more than one year after the NDOs in question, when the Biden DOJ updated its policy to better protect Congress after the first Trump DOJ obtained similar toll records without notifying affected Members and their staffs.[25] This too Jack Smith confirmed.[26] The A.O. had clarified this point to Senator Cruz long before Senator Cruz’s letter.
Notably, that law never required judges to ask about every NDO application on the chance it might implicate senators’ official phone records.[27] Furthermore, it is not clear this law would apply to the toll records at issue, as personal devices were not covered by the law. That is, until Republican senators changed the law last year to retroactively make Chief Judge Boasberg’s orders illegal and provide for taxpayer-funded payouts of at least $500,000 to Republican senators.[28]
Fifth, Senator Cruz says the NDOs Chief Judge Boasberg issued “presume that sitting United States Senators would destroy evidence or intimidate witnesses.”[29] The NDOs do not say Chief Judge Boasberg thought senators would destroy evidence or intimidate witnesses, and there is no evidence that he had these senators in mind, since he had no reason to surmise senators’ phone numbers were the subject of the order.[30] The relevant law says NDOs are appropriate if disclosure might reasonably lead to interference like evidence destruction or witness intimidation. The law does not say the interference would have to be committed by the person whose phone records are the subject of the subpoena.[31]
Sixth, Senator Cruz says it “makes it worse” if Chief Judge Boasberg did not know senators’ records were at issue because that means he “did not know who the targets were” and thus the NDOs had “no basis in fact.”[32] The likely basis in fact would be that President Trump and his co-conspirators had a pattern and practice of trying to tamper with evidence, intimidate witnesses, and jeopardize Jack Smith’s investigations.[33] The reason these subpoenas were issued in the first place was that the Trump conspirators had already tried to pressure these senators to overturn the 2020 election. That is how the telephones became relevant. There was every reason to believe the conspirators would repeat their misconduct if they knew, a finding that would have amply supported the issuance of NDOs, and Jack Smith’s testimony strongly implied this was the basis of his NDO applications.[34]
These clarifications find support in letters from the A.O., letters from Jack Smith’s attorneys, Jack Smith’s own sworn testimony, and ordinary and customary legal practice at the time. The House of Representatives should deliberate carefully before it considers articles of impeachment against any public official, and I urge you to review the source material we cite.
* * *
The House should also carefully consider the context in which these calls for impeachment arise. Since President Trump took office, federal judges and their families have been subjected to a surge of threats, harassment, and intimidation.[35] The Marshals Service is responding to unprecedented risk levels, and security appropriations have had to be increased. The pattern is clear: judges rule against the Administration; the President or his allies attack and spread misinformation; judges and their families receive threats, “swatting” attempts, and threatening stunts like pizzas in the name of a federal judge’s murdered son.[36] DOJ has repeatedly refused to assure us that they are investigating the pattern of threats for possible orchestration. Baseless calls for impeachment in this threat environment only add to the dangers facing these judges and their loved ones.
I hope these clarifications are helpful. I believe we all want a safe and independent federal judiciary.
Sincerely,
[1] In his letter, Senator Cruz has issued a similarly meritless call for the impeachment of Judge Deborah Boardman, citing a sentencing decision with which he disagrees. That demand contradicts basic law and history, as Chief Justice Roberts has made clear: “For more than two centuries, it has been established that impeachment is not an appropriate response to disagreement concerning a judicial decision. The normal appellate review process exists for that purpose.” Amy Howe, Chief justice rebukes Trump’s call for judicial impeachment, SCOTUSblog (Mar. 18, 2025). A notice of appeal has been filed regarding that sentencing, so it remains an active judicial proceeding, not a proper subject of partisan legislative pressure.
[2] Alan Feuer, Stalled Contempt Inquiry Into Deportation Flights Springs Back to Life, N.Y. Times (Nov. 19, 2025).
[3] Ryan J. Reilly et al., Federal judge targeted by Trump for impeachment is a bipartisan appointee with a three-decade career in Washington, NBC News (Mar. 19, 2025).
[4] In re Politico LLC, No. MC 25-7 (JEB), 2025 WL 2029757, at *2 (D.D.C. July 21, 2025).
[5] Breanne Deppisch, Boasberg’s role in ‘Arctic Frost’ probe sparks fury from GOP senators, despite local rules, Fox News (Nov. 1, 2025).
[6] Id.
[7] Piper Hudspeth Blackburn, Trump administration files another misconduct complaint against a federal judge, CNN (July 28, 2025).
[8] Id.
[9] Letter from Hon. Eric S. Schmitt et al. to Hon. Sri Srinivasan (Nov. 17, 2025).
[10] Katherine Tully-McManus, House passes 2 more funding bills – with 4 more to go, Politico (Jan. 14, 2026).
[11] Jeff Overley, ‘It’s A War Man’: Trump’s Deputy AG Unloads on Judges, Bars, Law360 (Nov. 7, 2025).
[12] Letter from Hon. Ted Cruz to Hon. Mike Johnson at 2 (Jan. 7, 2026).
[13] Letter from Robert J. Conrad, Jr., to Hon. Charles E. Grassley at 1 (Dec. 1, 2025); Fed. R. Crim. P. 6(e)(6). See also D.D.C. Crim. R. 6.1.
[14] Deposition of Jack Smith, Former Special Counsel, Before the H. Comm. On the Judiciary, 119th Cong. at 38 (Dec. 17, 2025) (transcript).
[15] Letter from Robert J. Conrad, Jr., supra note 13, at 1.
[16] Letter from Hon. Ted Cruz, supra note 12, at 2.
[17] U.S. S. Comm. on the Judiciary, Press Release, Biden FBI Spied on Eight Republican Senators as Part of Arctic Frost Investigation, Grassley Oversight Reveals. (Oct. 6, 2025).
[18] Deposition of Jack Smith, supra note 14, at 37-38. See also Letter from Lanny A. Breuer & Peter Koski to Hon. Charles E. Grassley at 1 (Oct. 21, 2025).
[19] Impeachment: Holding Rogue Judges Accountable: Hearing Before the Subcomm. on Fed. Cts., Oversight, Agency Action & Fed. Rts. of the S. Comm. on the Judiciary, 119th Cong. (2026) [hereinafter Hearing on Impeachment] (statement of Sen. Ted Cruz).
[20] Deposition of Jack Smith, supra note 14, at 18.
[21] Id.
[22] See infra notes 24-25.
[23] Letter from Hon. Ted Cruz, supra note 12, at 2.
[24] Letter from Robert J. Conrad, Jr., supra note 13, at 1.
[25] Ryan Tarinelli, DOJ watchdog review sparks change to policy on lawmaker records, Roll Call (Dec. 10, 2024).
[26] Deposition of Jack Smith, supra note 14, at 42.
[27] The operative provisions were passed not in 2004, as Senator Cruz asserts, but in 2020—in response to the Trump DOJ’s actions. See Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. FF, tit. IV, 134 Stat. 1182.
[28] See 2 U.S.C. § 6628.
[29] Letter from Hon. Ted Cruz, supra note 12, at 2-3.
[30] See In re Application of USA for 2705(b) Nondisclosure Order for Grand Jury Subpoena #GJ20230524-E0361, No. 23-sc-1256 (D.D.C. May 25, 2023); In re Application of USA for 2705(b) Nondisclosure Order for Grand Jury Subpoena #GJ[REDACTED], No. 23-sc-1257 (D.D.C. May 25, 2023).
[31] See 18 U.S.C. § 2705(b).
[32] Hearing on Impeachment, supra note 19 (statement of Sen. Ted Cruz).
[33] See Deposition of Jack Smith, supra note 14, at 38-39.
[34] Id.
[35] Lawrence Hurley, Judges who ruled against Trump say harassment and threats have changed their lives, NBC News (Dec. 23, 2025).
[36] Ned Parker et al., These judges ruled against Trump. Then their families came under attack., Reuters (May 2, 2025).
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