A federal officer shot and killed a woman in Minneapolis on Wednesday, shortly after the Trump administration deployed thousands of immigration agents to the city. Although the full circumstances of the killing remain unclear, video of the shooting shows an officer opening fire on the woman as she drove away.
Realistically, there’s virtually no chance that President Donald Trump’s Justice Department will bring federal charges against the officer who killed this woman. Trump already claimed on TruthSocial, his personal social media site, that the officer shot the woman in “self defense.” (The officer could potentially be prosecuted after Trump leaves office.)
But many local officials are quite upset about this incident. Minneapolis Mayor Jacob Frey gave a press conference Wednesday afternoon, in which he told US Immigration and Customs Enforcement to “get the fuck out of Minneapolis.” If further investigations reveal that the shooting was not legally justified, state prosecutors could potentially charge the officer responsible with a homicide crime.
The Supreme Court’s Republican majority has made it very difficult for private citizens to sue federal law enforcement officers who break the law. But can a federal officer actually be charged with, and convicted of, violating a state criminal law?
Until fairly recently, the law was favorable to federal officials who allegedly violate state criminal laws while they carry out their official duties. The seminal case, known as In re Neagle (1890), held that a deputy US marshal who shot and killed a man could not be charged with murder in state court, because this federal officer did so while acting as a bodyguard for a US Supreme Court justice.
Last June, however, the Supreme Court handed down Martin v. United States (2025), which held that Neagle does not always protect federal officials who violate state law.
The rule announced in Martin is vague, so it is unclear how it would apply to the shooting in Minneapolis. But the gist of the ruling is that a federal officer is only protected if they can demonstrate that “their actions, though criminal under state law, were ‘necessary and proper’ in the discharge of their federal responsibilities.”
If the officer responsible for the Minneapolis killing broke Minnesota law, in other words, any prosecution against them would turn on whether the courts decide shooting this woman was a “necessary and proper” exercise of the officer’s official duties.
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