Experts question Kristi Noem calling Renee Good a 'domestic terrorist.' Here's what it means

Homeland Security Secretary Kristi Noem described the actions of Renee Nicole Good, a Minneapolis woman fatally shot by an Immigration and Customs Enforcement officer, as "domestic terrorism." 

Noem said Good refused to obey orders to get out of her car and "weaponize(d) her vehicle" and "attempted to run" over an officer. Minnesota officials dispute Noem’s account, citing videos showing Good attempting to drive away.

Minnesota Attorney General Keith Ellison, a member of the state’s Democratic-Farmer-Labor party, said Jan. 8 on CNN that Noem’s statement is "an abuse of the term" domestic terrorism. 

The Trump 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 prioritize threats including "violent efforts to shut down immigration enforcement," saying domestic terrorists were using violence to advance "extreme views in favor 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 neighborhood where she was fatally shot. She was a United States citizen and had no criminal background, The Associated Press reported. Good’s ex-husband told the 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.

The Trump administration has ramped up Minneapolis immigration enforcement in recent weeks, following news reports about fraud in the Somali community.

What is domestic terrorism?

Federal agencies have their own definitions of domestic terrorism.

The FBI, citing a specific section of the U.S. 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, according to a 2020 memo.

Homeland Security 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 characterize 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 authorizes the U.S. 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 overuse or citing it to obscure other ideological motivations such as white supremacy.

A makeshift memorial honoring the victim of a fatal shooting involving federal law enforcement agents is taped to a post near the site of the previous day's shooting, Jan. 8, 2026, in Minneapolis. (AP)

The Trump administration has broadened the domestic terrorism label

The DHS rhetoric is similar to another immigration enforcement-related shooting in October. During DHS’s months-long Chicago immigration crackdown dubbed "Operation Midway Blitz," a Border Patrol agent shot U.S. citizen Marimar Martinez five times. 

A DHS press 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."

A federal judge granted prosecutors’ motion 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 DHS. 

After conservative activist Charlie Kirk’s murder, Trump issued a Sept. 25 memo ordering the attorney general to expand domestic terrorism priorities to include "politically motivated terrorist acts such as organized 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 organization.

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, Brennan Center for Justice director of liberty and national security, 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 Rep. 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 Justice Department Counsel for Domestic Terrorism, wrote Dec. 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 toward 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 since Good was trying to drive away to "characterize 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 labeling 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 characterize anything she wants as domestic terrorism. She is doing so without any facts to go on."

Shirin Sinnar, Stanford 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 after the Minneapolis shooting 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 U.S. Code," pointing to 18 U.S. Code Chapter 113B. "So a government official calling her a domestic terrorist isn't supported in the law, and is entirely pejorative and prejudicial."

RELATED: Nihilistic violent extremism: What the FBI term means and why experts warn against overuse