U.S. federal law enforcement repeatedly misused rubber bullets, pepper balls, tear gas cannisters, and flash-bang grenades in harmful and dangerous ways against journalists, medics, and peaceful protestors during demonstrations in Los Angeles, California over the summer of 2025, Physicians for Human Rights (PHR) argues in a new amicus brief filed in L.A. Press Club v. Kristi Noem at the U.S. Court of Appeals for the Ninth Circuit.
Drawing on nearly four decades of PHR research about the potential health harms of crowd-control weapons, PHR medical and legal experts reviewed court declarations and news reports on Trump administration immigration agents’ excessive and reckless force against peaceful demonstrators as well as journalists, medics, and bystanders at the L.A. protests. PHR finds that the court record and reporting indicate that federal agents used crowd-control weapons in a manner inconsistent with international standards such as the United Nations Guidance on Less-Lethal Weapons in Law Enforcement.
“Crowd control weapons like rubber bullets, pepper balls, and tear gas may be labeled ‘less lethal,’ but medical research shows they can cause serious injury or even death. The risk of grave harms is even greater when law enforcement misuses these weapons as the court record indicates was the case in Los Angeles this summer,” said Michele Heisler, MD, MPA, medical director at PHR and professor of internal medicine and public health at University of Michigan.
“The court record shows that federal law enforcement in Los Angeles targeted the heads and faces of journalists and protestors with rubber bullets. They fired even at the backs of journalists and protestors,” said Dr. Heisler. “Federal agents also deployed vast quantities of tear gas and shot pepper balls and tear gas cannisters into groups of protestors when there was no evidence agents were being threatened. Officials fired dangerous disorientation devices like flashbangs into large crowds. The examples that the court highlighted show how federal law enforcement repeatedly misused crowd control weapons in a manner that risked serious injury to non-violent protestors, journalists, and bystanders.”
PHR’s analysis draws on a wide range of medico-legal documentation of the health and human rights harms of crowd-control weapons around the world. This includes Lethal in Disguise, a seminal report that offers the best available evidence of the deaths and severe injuries caused by kinetic impact projectiles (such as rubber bullets), chemical irritants (such as tear gas), and other crowd-control weapons in the United States and around the world.
PHR’s amicus brief highlights some of the severe injuries documented in the court record and news accounts as resulting from federal agents’ misuse of crowd-control weapons. For example, Ryanne Mena, a journalist who was covering protests in Paramount, was hit just an inch above her right ear with what is believed to have been a rubber bullet, resulting in a concussion. Alexander Nadolishny, a 55-year-old engineer attending the protests in Camarillo, was hit in the ear with a pepper ball as he was running away from the protest. Agents fired tear gas on a group of protestors in Paramount, including the 52-year-old Diya Cruz, which triggered an asthma attack for Cruz.
Following the summer 2025 protests in Los Angeles, a coalition of journalists, legal observers, protestors, and journalist associations sued the Department of Homeland Security (DHS) in the U.S. District Court for the Central District of California. Their complaint alleged that in June, Immigration and Customs Enforcement (ICE) launched an operation to arrest immigrants in and around Los Angeles, “setting new sky-high targets for daily immigration arrests and expanding the scope of its operations far beyond immigrants with criminal histories.” Plaintiffs alleged that DHS responded to protests over these immigration raids with excessive force by using tear gas, pepper balls, chemical spray, and rubber bullets.
The court granted the preliminary injunction on September 10, finding that federal agents’ use of force has been and would continue to be disruptive to both peaceful protest and media coverage.
In its new amicus brief, PHR urges the U.S. Court of Appeals for the Ninth Circuit to uphold the district court’s granting of the preliminary injunction in order to prevent the further dangerous and harmful misuse of crowd control weapons that has been visited upon protestors and journalists in Los Angeles. The amicus brief was filed on behalf of PHR by Gerson H. Smoger, JD, PhD, Raymond P. Boucher, JD, Payal Shah, JD, and Kimberly Saltz, JD.
Read PHR’s full amicus brief here.
Physicians for Human Rights (PHR) is a New York-based advocacy organization that uses science and medicine to prevent mass atrocities and severe human rights violations. Learn more here.