In the year of our lord 2026, a federal judge getting real frustrated at a Trump administration lawyer is practically its own genre. On Monday, U.S. District Judge Sanket Bulsara of the Eastern District of New York added the latest entry, barring Assistant U.S. Attorney Thomas Price from ever appearing again in Benitez v. Department of Homeland Security. (That’s the suit alleging that federal immigration officers in New York arrest people based on their ethnicity and without the warrants the law requires.)

I need a moment for the harshness of the judge’s punishment — honestly, it’s cold as ice.

The problem was a November 4 letter with Price’s name on it. The letter told the court that an injunction in a related case covered only the one petitioner in that case. The injunction came from U.S. District Judge Gary Brown, a Trump appointee, in Sanchez Alfaro v. Mullin. That case was about ICE’s warrantless arrest of a Long Island man with Special Immigrant Juvenile status, and officers later admitted they’d grabbed the wrong guy. Brown had already called the government’s arguments “both factually incorrect and legally spurious.” And his injunction also wasn’t about one guy, it reads: “Before effecting a civil immigration arrest in this judicial district, ICE shall obtain a valid warrant of arrest in advance.” (There’s an exception for people likely to flee.)

“In this judicial district”… it’s right there in the text.

You can’t even write this off as a sloppy read because Price had also filed briefs in Sanchez Alfaro arguing that the district-wide warrant requirement would be hard to comply with. He knew exactly how big the order was, hell, he’d complained about how big it was! Then he signed a letter to another judge in the same courthouse saying it was tiny.

Bulsara wasn’t confused about what happened. From the bench, he said Price’s letter was written in “bad faith, a deliberate attempt to mislead the Court, perpetuate a fraud on the tribunal, and violate[s] obligations under Rule 11.” He said “the only conclusion that can be drawn from these statements is that they’re made in bad faith.” He also said this wasn’t a one-off but “a pattern of dissembling, obfuscation, and frankly outright misrepresentation that bled from Alfaro into this case.”

He also sounded a little hurt, because he thought he’d been doing the government a favor:

When I issued the order that I issued in this case, I actually did it fully expecting I was giving a gift horse to the respondents. … I was flabbergasted by the response.

Turns out you can look a gift horse in the mouth, you just shouldn’t lie to the judge about what you saw.

The minute order Bulsara entered after the hearing is drier, but it’s no gentler:

As stated on the record, the Court has found prima facie Rule 11 violations based on the contents of Defendants’ November 4 letter 111. AUSA Price is barred from continuing appearances in this case and must file a notice of withdrawal no later than November 13, 2026.

The order also gives the office’s line attorneys a chaperone:

Every future filing in this docket must be signed by Richard Hayes, Chief of the Civil Division of the U.S. Attorney’s Office for the Eastern District of New York, or someone at his supervisory level or higher.

In other words, nothing gets filed in this case without a grown-up’s signature on it.

The office as a whole is also on the hook. Under Rule 11(c)(3), it has to show cause “why Rule 11 sanctions should not be imposed or imposed pursuant to 28 U.S.C. § 1927 or the Court’s inherent power.” That’s three separate grounds for sanctions in a single sentence. Two other AUSAs whose names appear in the letter’s signature block have until November 16, the same deadline as the show-cause response, to file sworn declarations explaining how much they wrote, edited, or supervised the letter. Bulsara indicated he’ll likely disqualify them too unless they can show they weren’t involved. He told Hayes to think about pulling Price from his other cases before the court as well, adding: “Your office is on notice.” Hayes didn’t address the misconduct allegations at the hearing and asked for time to review the transcript.

Then there’s the threat that really matters:

The Court has issued a warning about the consequence should the Court discover any future misrepresentation or false statement (either by counsel or any witness or declarant): after an opportunity to be heard, should preliminary findings be confirmed, the Court will enter a default judgment in this case in favor of Plaintiffs, with the only issue for resolution to be remedies to be imposed.

It’s also part of a pattern. In Florida, Judge Roy Dalton put DOJ lawyers on blast for pretending inconvenient law doesn’t exist. In New Jersey, Judge Zahid Quraishi tossed a supervisory AUSA out of his courtroom while trying to figure out who’s even running the office. In Rhode Island, Judge Mary McElroy nuked the department for an “appalling lack of candor” over its subpoena campaign. In Minnesota, Chief Judge Patrick Schiltz ran out of patience with ICE treating court orders as optional. And the Comey prosecution got the benchslap treatment before it ever got near a jury. The judges are Bush appointees, Trump appointees, Obama appointees, and Biden appointees. They keep reaching the same conclusion.

For decades the Justice Department walked into court with the presumption of regularity: judges took its word because its word was usually good. Price’s office is now on notice that it’s lost that presumption, and at this point it’s hard to argue any other office is in a different position.

Earlier: A Judge Just Turned The Government’s Own ‘Reconsider’ Motion Against Them And It’s Glorious
DOJ Gets Nuked By RI Judge For ‘Appalling Lack Of Candor’
Judge Tosses DOJ Lawyer From Courtroom As New Jersey U.S. Attorney’s Office Descends Into Chaos
‘Don’t Hide The Ball’: Judge Puts DOJ’s Lawyers On Blast
Bush-Appointed Federal Judge To ICE: Comply With Court Courts. ICE: You’ve Got Us There!
ICE Dodges Courtroom Showdown, But Federal Judge Isn’t Backing Down
Comey Prosecution Gets The Benchslap Treatment, Because Of Course

Kathryn Rubino is a Senior Editor at Above the Law, host of The Jabot podcast, and co-host of Thinking Like A Lawyer. AtL tipsters are the best, so please connect with her. Feel free to email her with any tips, questions, or comments and follow her on Twitter @Kathryn1 or Bluesky @Kathryn1

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