Was Renee Good a 'domestic terrorist?'

On Jan. 7, American citizen Renee Good was fatally shot by an ICE officer. Senior Trump administration officials almost immediately claimed that she was guilty of "domestic terrorism." Vice President J.D. Vance described Good's conduct as "classic terrorism." Richard Luscombe, "Trump administration unleashes torrent of untruths after woman shot dead by ICE | Trump administration," The Guardian (Jan. 9, 2026. As DHS Director Kristy Noem chimed in, Good "proceeded to weaponize her vehicle and she attempted to run a law enforcement officer over. This appears as an attempt to kill or to cause bodily harm to agents, an act of domestic terrorism." Rev, Jan. 16, 2026.   

Articulations regarding "domestic terrorism" did not start with this incident. The FBI summary of the 1996 Oklahoma City bombing by a U.S. citizen came close. It was described as "the worst act of homegrown terrorism in the nation's history." "Oklahoma City Bombing," FBI (undated. The post-9-11 Patriot Act mentions only "international terrorism." "The USA PATRIOT Act: Preserving Life and Liberty," (p. 1, fourth bullet point).  

Last September, President Trump directed the following entities to act within their respective spheres to combat domestic terrorism: National Joint Terrorism Task Force, U.S. Attorney General, Secretary of the Treasury, IRS Commissioner and the Homeland Security Secretary. White House, "Countering Domestic Terrorism and Organized Political Violence," National Security Presidential Memorandum/NSPM-7 (Sept. 25, 2025).       

Last month, Attorney General Pam Bondi acted upon the President's directive in rather broad terms. Thus, "domestic terrorists use violence or the threat of violence to advance political and social agendas, including opposition to law and immigration enforcement; extreme views in favor of mass migration and open borders; adherence to radical gender ideology, anti-Americanism, anti-capitalism, or anti-Christianity; support for the overthrow of the United States Government; hostility towards traditional views on family, religion, and morality; and an elevation of violence to achieve policy outcomes, such as political assassinations." Pam Bondi, "Bondi Memo on Countering Domestic Terrorism and Organized Political Violence," p. 1 ⁋ 1. Thus, "where domestic terrorism is encountered or suspected, law enforcement agencies shall refer such matters to the [above] Joint Terrorism Task Forces ... for the exhaustive investigation contemplated by NSPM-7. Id., p. 2 ⁋ 2. 

One week later, Deputy Attorney General Todd Blanche accused Minnesota Governor Tim Waltz and Minneapolis Mayor Jacob Frey of terrorism. As Blanche wrote on X: "Minnesota['s] insurrection is a direct result of a FAILED governor and a TERRIBLE mayor encouraging violence against law enforcement. It's disgusting. Walz and Frey‒I'm focused on stopping YOU from your terrorism by whatever means necessary. This is not a threat. It's a promise." Todd Blanche, X@DAGToddBlanche (Jan. 14, 2026). One can instantly detect how readily the term terrorism is used and abused. 

This op-ed does not focus on choosing sides. It instead seeks to examine whether the relevant federal statutes portray a colorable argument for: (a) reasoned application of the U.S. domestic terrorism statutes to protestors such as Good; or (b) whether the DOJ could have charged her only with assault or attempted murder under 18 U.S.C. § 111 or § 1113. Many readers will conclude that launching either charge would have rendered Orson Wells' novel 1984 no longer fiction.

An objective assessment begins with the precedents for defining terrorism. The term terrorism evolved from the Reign of Terror during the 18th century French Revolution. Modernly, the U.N. offers the most instructive description: "[T]errorism can be broadly understood as a method of coercion that utilizes or threatens to utilize violence in order to spread fear and thereby attain political or ideological goals. Contemporary terrorist violence is thus distinguished in law from 'ordinary' violence by the classic terrorist 'triangle': A attacks B, to convince or coerce C to change its position regarding some action or policy desired by A. The attack spreads fear as the violence is directed, unexpectedly, against innocent victims, which in turn puts pressure on third parties such as governments to change their policy or position." "U.N. Doha Declaration: Introduction to International Terrorism," (2018), p.1.

This associated international regime found its way into U.S. law in 1992: "international terrorism means activities that ... appear to be intended--(i) to intimidate or coerce a civilian population; (ii) to influence the policy of a government by intimidation or coercion; or (iii) to affect the conduct of a government by mass destruction, assassination, or kidnapping." 18 U.S. Code § 2331. Its content undoubtedly incorporates terrorist descriptions drawn from international treaties to which the US is a party.

Good could not possibly have been a terrorist in this classical sense. Even if she (A) had attacked the officer who shot her (B), her actions did not morph into an intent to cause the federal government (C) to cease its Minneapolis operations. Her specific comment to her killer‒just before he shot her‒was "That's fine dude, I am not mad at you." Ted Johnson, "Networks Air ICE Officer's Cell Phone Footage of His Shooting of Minneapolis Woman," Deadline News (Jan. 9, 2026).

To accurately label Good as a domestic terrorist, the above Attorney General's Memo and the President's White House policy directive would have to dovetail with relevant U.S. statutes. These are the criminal Code Title 18 federal statutes A.G. Bondi relies upon in her above memo. Page 4 thus addresses assaulting, resisting or impeding federal officers (§ 111); obstruction during civil disorders (§ 231); conspiracy to impede or injure officer (§ 372); attempting to kill a federal officer (§ 1114); and potentially gilding the lily via providing material support for terrorist activity (§ 2339 et seq.).

Were Good still alive, a domestic terrorism charging allegation would be rooted in 18 U.S.C. § 1114. It criminalizes "[w]hoever kills or attempts to kill any officer or employee of the United States ... while such officer or employee is engaged in ... performance of official duties...." The President accused Good of attempting to run over the ICE shooter with her car‒an accusation repeated by Kristy Noem. See Mike Stunson, "Minnesota Officials Dispute Trump and Noem's Claims that Woman Killed by ICE Tried to Run Over Agent," Forbes (Jan. 7, 2026).

Reporters, on the other hand, countered that analyses of video footage by multiple news outlets indicates that she was attempting to maneuver her car away from federal agents at the time of the shooting. Rachael Levinson-Waldman, "Labeling Renee Good a 'Domestic Terrorist' Distorts the Law," Brennan Center for Justice (Jan. 16, 2026). The videos, assuming their conclusiveness, would have undermined the validity of a § 1114 allegation charging Good as a terrorist‒or others who will no doubt be shoehorned into this more political than legal designation. 

One should, of course, not heed this writer, nor adopt the conclusion of any other contributor‒without personally viewing the widely available footage of the Good incident. Perhaps the best available coverage is provided by the graphic depiction, with its associated narrative, available in Ray Sanchez, "Whistles, then gunfire: How the deadly ICE shooting unfolded in Minneapolis," CNN (Jan. 10, 2026). 

In conclusion, one should also not shy away from taking a position on whether Good was a domestic terrorist. The absence of a federal investigation (of the officer) will spawn eternal conspiracy theories about who was the actual "terrorist." Good? The shooter? The federal government? The videos to date indicate that the officer in question was juggling both his phone and camera. That seems to have incapacitated his ability to reasonably interpret any threat. Good had turned her vehicle away from him. He then commenced his rapid-fire volley. He fired not one, but three shots. Rather than being injured, he casually walked to and away from her vehicle, notwithstanding the President's inaccurate bluster about Good's running over the shooter.

Any prosecution of Good, had she survived, would have to be tethered to a relevant statute in the U.S. Criminal Code. It would have been, at most, an assault or attempted murder charge under 18 USC § 111 or § 1113, not feigned domestic terrorism under § 1114. There is an additional impediment to using that statute to prosecute in the name of domestic terrorism. That term does not appear in § 1114. Also, Congress instead focused on international terrorism. As subsection (b) of the statute provides: "There is extraterritorial jurisdiction [for acts beyond U.S. borders] over the conduct prohibited by this section."

Future prosecutors will presumably prefer the jury to focus on "domestic terror," rather than just attempted murder. But in the case of Renee Good, if there was in fact an act of terror afoot, the proverbial shoe appears to be on the other foot. As we say in the law, res ipsa loquitur.