Overview[1]

Colleen Constance Kollar was born in New York City on April 17, 1943. Her paternal grandparents immigrated to the United States from Hungary, and her father was an environmental engineer. Miss Kollar adopted her hyphenated surname when she married John Theodore Kotelly, an attorney based in Washington, D.C.

After earning a bachelor’s degree from the D.C.-based Catholic University of America in 1965, and a JD degree from Catholic University’s Columbus School of Law three years later, Ms. Kollar-Kotelly then served as:

• a law clerk for Judge Catherine Kelly of the District of Columbia Court of Appeals in 1968-1969
• an attorney in the U.S. Justice Department’s Division of Criminal Appeals from 1969-1972
• chief legal counsel for St. Elizabeth’s Hospital in Washington, D.C. from 1972-1984
• an associate judge of the Superior Court of the District of Columbia, a position for which he was nominated by President Ronald Reagan, from 1984-1997

On January 7, 1997 President Bill Clinton nominated Kollar-Kotelly for a judgeship with the United States District Court for the District of Columbia. She was confirmed on a voice vote of the Senate on March 20, 1997, and she received her commission six days later.

While Kollar-Kotelly continued to hold her position with the U.S. District Court:

• Supreme Court Chief Justice William Rehnquist appointed her to serve on the Judicial Conference Committee on Financial Disclosure from June 2000 through May 2002, and
• Rehnquist then appointed her as Presiding Judge of the United States Foreign Intelligence Surveillance Court (FISC), where she went on to serve for seven years until 2009.

Kollar-Kotelly assumed  senior status with the United States District Court for the District of Columbia on February 21, 2023.

Ruling on NSA Surveillance

In 2004 Kollar-Kotelly issued a ruling in the secret Foreign Intelligence Surveillance Court (FISC), wherein she authorized the National Security Agency’s (NSA) bulk collection of Internet metadata — e.g., email addresses and headers as well as telephone numbers, but not the actual content of the emails or phone calls — under the Foreign Intelligence Surveillance Act (FISA). As George Mason University Professor James P. Pfiffner put it, “Kollar-Kotelly … determined that the bulk collection of [I]nternet data could be justified by Pen Register/Trap [and] Trace authority.”[2]

Also in her ruling, the judge instructed the NSA to thenceforth eliminate as much privacy intrusion as possible by practicing certain “minimization procedures” such as the strict “segregation of data,” which meant that:

• the collected metadata had to be physically separated from other NSA-held data sets;
• access to the segregated data was strictly limited to just 10 NSA administrators;
• searches of the collected data required approval from select NSA officials and could only be conducted where there was a “reasonable, articulable suspicion that the person is associated with specified foreign terrorist organizations”;
• the collected metadata must be destroyed within four-and-a-half years

Ruling on the Permissibility of Carrying Guns in America’s National Parks

On December 30, 2008, the Brady Campaign to Prevent Gun Violence, the National Parks Conservation Association, and the Coalition of National Park Service Retirees jointly sued the George W. Bush administration in an effort to block the continuance of a newly enacted Bush policy permitting people to “possess, carry, and transport concealed, loaded, and operable firearms” in national parks that were located in states where the concealed carry of guns was legal.

On March 19, 2009, Kollar-Kotelly responded to that lawsuit by issuing a 44-page Preliminary Injunction against the Bush policy, which the judge: (a) characterized as “astoundingly flawed,” and (b) criticized for having been enacted without a National Environmental Policy Act [NEPA] review. The Bush White House, she elaborated, had:

“ignored (without sufficient explanation) substantial information in the administrative record concerning environmental impacts, including (i) Defendants’ own long-standing belief under the previous regulations that allowing only inoperable and stored firearms in national parks and wildlife refuges was necessary to safeguard against certain risks to the environment, and (ii) the almost universal view among interested parties that persons who possess concealed, loaded, and operable firearms in national parks and wildlife refuges will use them for any number of reasons, including self-defense against persons and animals (all of which suggests that the Final Rule will have some impact on the environment).”

Added the judge in her ruling:

“[T]he Court holds that Plaintiffs are highly likely to prevail on the merits of their NEPA claims. The Court also holds that Plaintiffs have met their burden to show a likelihood of irreparable harm, the absence of significant harm to other interested persons or entities, and that the public interest weighs in favor of preliminary injunctive relief. Having balanced all of these considerations and found that they weigh in favor of issuing a preliminary injunction, the Court shall GRANT Plaintiffs’ Motion for a Preliminary Injunction.”

Blocking President Trump’s Ban on Transgenders in the Military

On July 26, 2017, President Trump posted a tweet declaring that his administration — in a dramatic departure from the policy of Barack Obama before him — “will not accept or allow transgender individuals to serve in any capacity in the U.S. military.” Exactly two weeks later, on August 9, five transgender military personnel responded to Trump’s tweet by filing a lawsuit, known as Jane Doe v. Trump, requesting a court order to prevent the Trump policy from going into effect. “The directive to reinstate a ban on open service by transgender people violates both the Equal Protection component of the Fifth Amendment and the Due Process Clause of the Fifth Amendment to the United States Constitution,” said the suit. Judge Kollar-Kotelly was assigned to preside over this case.

On August 25, 2017 Trump followed through on his stated position, issuing a “Presidential Memorandum that barred transgender people from serving in the American armed forces. The order was rooted in the premise that not only would such individuals be a financial burden to the military because of the costs associated with sex reassignment and other related procedures, but that their presence would also “hinder military effectiveness and lethality” and “disrupt unit cohesion.”

According to CNN: “Trump administration lawyers … asked the judge to dismiss the lawsuit, arguing that it was premature because the Pentagon is currently studying how to implement the President’s directive and no action would be taken until after the policy review is completed. They also argued that ‘federal courts owe the utmost deference to the political branches in the field of national defense and military affairs, both because the Constitution commits military decisions exclusively to those branches and because courts have less competence to second-guess military decision making.’”

But in a Memorandum Opinion issued on October 30, 2017, Judge Kollar-Kotelly rejected the Trump administration’s claim that the newly proposed policy was technically still subject to review. “The [Presidential] Memorandum,” she wrote, “unequivocally directs the military to prohibit indefinitely the accession of transgender individuals and to authorize their discharge. [T]his decision has already been made. These directives must be executed by a date certain, and there is no reason to believe that they will not be executed.”

On October 30, 2017, Kollar-Kotelly issued a Preliminary Injunction that blocked Trump’s Executive Order of August 25. Characterizing transgender individuals as “a discrete group,” a “discernable class,” and a “subset of society,” she suggested that only “animus” or a “desire to harm a politically unpopular group” could explain why the President would wish to treat transgenders differently from other people seeking to join the armed forces.

Moreover, Kollar-Kotelly ruled that the plaintiffs “have established that they will be injured by these [Trump administration] directives, due both to the inherent inequality they impose, and the risk of discharge and denial of accusation that they engender.” The judge also said of the President’s policy: “All of the reasons proffered by the President for excluding transgender individuals from the military in this case were not merely unsupported, but were actually contradicted by the studies, conclusions and judgment of the military itself.” Indeed, she emphasized, the administration’s arguments “wither away under scrutiny.”

Maintaining that the plaintiffs in this case were likely to prevail on their claim that the Trump policy represented an assault on their Fifth Amendment rights, Kollar-Kotelly wrote as well:

“Further delay [on issing an injunction] would only serve to harm the Plaintiffs. Given these circumstances, the Court is in a position to preliminarily adjudicate the propriety of these directives, and it does so here. The Court holds that Plaintiffs are likely to succeed on their Fifth Amendment claim. … The Court finds that a number of factors—including the sheer breadth of the exclusion ordered by the directives, the unusual circumstances surrounding the President’s announcement of them [via a Twitter post], the fact that the reasons given for them do not appear to be supported by any facts, and the recent rejection of those reasons by the military itself—strongly suggest that Plaintiffs’ Fifth Amendment claim is meritorious.”

As Ballotpedia.org explains: “Judge Kollar-Kotelly’s order had the effect of reverting to the policy [that had been] in existence prior to the issuance of [Trump’s] August 2017 memorandum.”

Ruling on Trump’s Department Of Government Efficiency (DOGE)

At the start of his second term in office, President Trump issued a January 20, 2025 executive order establishing the Department of Government Efficiency (DOGE) as a temporary federal initiative headed by billionaire tech entrepreneur Elon Musk and tasked with ridding the government, as much as possible, of fraud, needless bureaucracy, and wasteful expenditures. To faciliate its efforts against fraud in particular, DOGE was given wide-ranging access to federal payment systems, including those of Social Security and Medicare.

Rebelling against the DOGE team’s capacity to access the personal Treasury Department payment records of the millions of Americans who had ever engaged in any financial transactions with the federal government, an alliance of labor unions and advocacy groups — most notably the Alliance for Retired Americans, the American Federation of Government Employees, and the Service Employees International Union — sued DOGE and the Treasury Department in early February in an effort to restrict that access thenceforth. As Fedscoop.com notes, the information that was being shared with DOGE included such things as people’s names, Social Security numbers, birth dates, birth places, home addresses and telephone numbers, email addresses, and bank account information. Citing the Privacy Act of 1974 and the Internal Revenue Code’s protections for taxpayer information, the plaintiffs asked Judge Kollar-Kotelly, who was assigned to preside over the case, to put “an immediate stop” to the “systematic, continuous, and ongoing violation of federal laws that protect the privacy of personal information contained in federal records.”

In response to the lawsuit, Kollar-Kotelly on February 6, 2025 issued a Temporary Restraining Order (TRO) greatly limiting DOGE’s access to Treasury Department data. Specifically, the TRO stipulated that: (a) Treasury “will not provide access to any payment record or payment system of records maintained by … the Bureau of Fiscal Service”; (b) the only exceptions to that restriction would be granted to a pair of DOGE-linked “special government employees” — Cloud Software Group CEO Tom Krause and software engineer Marko Elez — who would be permitted to access Treasury data; and (c) that data would be in “read-only” form, meaning that Krause and Elez would be unable to alter it in any way. Also on February 6, Fedscoop.com reported: “The order from Judge Kollar-Kotelly will remain active until the court rules on a forthcoming preliminary injunction motion from the plaintiffs.”

But in early March 2025 — after the government had implemented some controls on data access and the plaintiffs had failed to prove their claim that they would suffer “irreparable injury” if DOGE employees were to somehow gain access to Treasury Department payment systems — Kollar-Kotelly denied the plaintiffs’ requests for a broader, longer-term Preliminary Injunction against DOGE. (NOTE: Judges are legally prohibited from issuing Preliminary Injunctions in any given case unless the plaintiffs are first able to demonstrate that they would suffer irreparable injury or harm in the absence of an injunction.) “If Plaintiffs could show that Defendants imminently planned to make their private information public or to share that information with individuals outside the Federal government with no obligation to maintain its confidentiality,” Kollar-Kotelly wrote in a March 7, 2025 Memorandum Opinion, “the Court would not hesitate to find a likelihood of irreparable harm. But on the present record, Plaintiffs have not shown that Defendants have such a plan.” “If circumstances change,” she added, “Plaintiffs are free to return to Federal court to seek any proper emergency remedy.”

Pro-Abortion Bias

Judge Kollar-Kotelly once suggested the possibility that the 13th Amendment to the U.S. Constitution guaranteed women’s inherent right to abortion because of its prohibition against both “slavery” and “involuntary servitude” — on the premise that being forced to endure an unwanted pregnancy is akin to enslavement. And after the Supreme Court’s 2022 Dobbs decision, which overturned Roe v. Wade, determined that the 14th Amendment included no right to abortion, she reasoned that “it is entirely possible that the Court might have held in Dobbs that some other provision of the Constitution provided a right to access reproductive services had that issue been raised.” “Kollar-Kotelly noted that there is some legal scholarship suggesting that the 13th Amendment — which was ratified at the end of the Civil War and sought to ban slavery and ‘involuntary servitude’ — provides just such a right,” reported Politico in February 2023.

In May 2024, Kollar-Kotelly sentenced nine pro-life, anti-abortion activists to federal prison for having “forcefully entered” the Washington (D.C.) Surgi-Clinic abortion facility in the District of Columbia, infamous for performing late-term abortion procedures, in October 2020. According to the Department of Justice (DOJ), in October 2020 the nine activists had “set about blockading two clinic doors using their bodies, furniture, chains and ropes” — actions that Kollar-Kotelly saw as vigilantism. In March of 2022, the DOJ charged the nine with “conspiracy against rights” and violating the federal Freedom of Access to Clinic Entrances Act (a.k.a. FACE Act), a 1994 statute signed by President Bill Clinton to outlaw any obstruction of access to — or any acts of vandalism against — abortion clinics, pregnancy centers, or church property. A number of lawmakers have pointed out that the FACE Act has been disproportionately applied against pro-life activists. Indeed, PJ Media reports: “[A]ccording to data obtained by Rep. Chip Roy’s office, 97% of convictions between 1997 and 2024 have been against pro-life activists. The suppression of free speech has resulted in people going to jail as ‘repeat offenders’ despite the non-violent nature of their demonstrations.”

The nine defendants in this particular case were sentenced to prison terms ranging from 10 months to 57 months. One of them was a 75-year-old Massachusetts woman named Paulette Harlow, whose husband, citing his wife’s declining health, begged Kollar-Kotelly for leniency. But the judge was not moved by the man’s pleas, replying that Mrs. Harlow should resolve to “make every effort to remain alive, to do the things that you need to do to survive” as part of the “tenets of your religion.”

It is further worth noting how Kollar-Kotelly treated 30-year-old Lauren Handy, the director of activism at the Progressive Anti-Abortion Uprising (PAAU), who was the lead organizer of the October 2020 demonstration at Surgi-Clinic. Not only did Ms. Handy receive the longest prison sentence of anyone in the group (57 months), but after the jury returned its verdict, the judge ordered that Handy and four of her co-defendants be immediately taken to jail for what she described as their “crime of violence.”

In response, Handy’s attorneys — Thomas More Society senior counsels Martin Cannon and Steve Crampton — filed a motion in which they argued that under federal law and binding precedents from the D.C. Circuit Court of Appeals and the U.S. Supreme Court, a FACE Act violation is not in fact a “crime of violence” and should not subject a defendant to pre-sentencing detention. They also argued that if Handy were to be released before sentencing, she would pose no risk to the public at large. “Ms. Handy is a prominent national nonprofit leader,” wrote the attorneys. “In 2017, she founded Mercy Missions, a mutual aid organization dedicated to helping families and mothers in crisis pregnancies and providing survival aid for houseless people. Her charitable work and desire to help people and particularly families have led to previous arrests and charges for, primarily, trespassing. There is no evidence that Ms. Handy poses a danger to the safety of any person or the community.”

Breitbart.com pointed out additional examples of the Judge Kollar-Kotelly’s harsh attitude toward Ms. Handy:

“Judge Kollar-Kotelly notably barred Handy’s attorneys from entering photos of the remains as evidence at trial. She also barred them from including a Live Action undercover video of Washington-Surgi Clinic abortionist Dr. Cesare Santangelo allegedly saying he would not assist a baby that is born alive in a botched abortion.”

Remarks About the January 6th Protesters

On January 20, 2025, President Trump issued an executive order granting sweeping pardons for nearly 1,500 defendants who had been punished legally for their participation in the January 6, 2021 breach of the U.S. Capitol building in Washington, D.C., plus commutations of the sentences of another 14 individuals.

In commentary to the media, Kollar-Kotelly said that Trump’s pardons and commutations “will not change the truth of what happened on January 6, 2021.” “What occurred that day is preserved for the future through thousands of contemporaneous videos, transcripts of trials, jury verdicts, and judicial opinions analyzing and recounting the evidence through a neutral lens,” she added. “Those records are immutable and represent the truth, no matter how the events of January 6 are described by those charged or their allies.”

The judge also said: “What role law enforcement played that day and the heroism of each officer who responded also cannot be altered or ignored. Grossly outnumbered, those law enforcement officers acted valiantly to protect the Members of Congress, their staff, the Vice President [Mike Pence] and his family, the integrity of the Capitol grounds, and the Capitol Building — our symbol of liberty and a symbol of democratic rule around the world. For hours, those officers were aggressively confronted and violently assaulted. More than 140 officers were injured. Others tragically passed away as a result of the events of that day.”

But Kollar-Kotelly’s claim that multiple people had died “as a result of the events of” January 6 was wholly untrue. Indeed, only one person was killed at the Capitol during the protest: a young female Trump supporter named was Ashli Babbitt, who was fatally shot by Capitol Police Lt. Michael Byrd. All other deaths that Democrats and media outlets have cited as having been somehow related to the events at the Capitol were nothing of the kind. For details, see Footnote #3 below. To view key information from Factcheck.org, see Footnote #3 below.[3]

In the course her remarks, Kollar-Kotelly also:

• drew comparisons between the Capitol protest and the “bloody” public response to the 1860 presidential election (of Abraham Lincoln) that shortly preceded the start of the U.S. Civil War;
• warned that American democracy was under threat and drew comparisons to “[Hugo] Chavez‘s Venezuela, Pinochet’s Chile, and Argentina’s ‘Dirty War'”;
• told a Florida man whom she had convicted and sentenced for his role in the Capitol protest that his “unlawful action” had done great damage “to our democracy” and “degrade[d] our Constitution” — all because the defendant and a likeminded “group of people who knew the [2020] election wasn’t stolen” nevertheless “rioted to install their preferred candidate.”

Blocking Trump’s Call for Proof-of-Citizenship for Voter Registration

On March 25, 2025, President Trump issued an executive order entitled “Preserving and Protecting the Integrity of American Elections,” which required “documentary proof of United States citizenship” for all people wishing to vote in American federal elections. This was a highly popular policy with the American people, as Fox News noted:

“Less than two weeks before the 2024 election, Gallup found that 84% of U.S. adults were in favor of requiring voters to show identification, and 83% supported requiring proof of citizenship when registering for the first time.

“When broken down by party, 67% of Democrats, 84% of Independents, and 98% of Republicans were in favor of mandating voter ID. The party breakdown over proof of citizenship was similar, with 66% of Democrats, 84% of Independents, and 96% of Republicans supporting the idea.”

Nonetheless, a number of self-described “voting rights groups” sued to prevent Trump’s order from taking effect. Attorneys for the plaintiffs claimed that a proof-of-citizenship requirement for federal voter-registration forms would unjustifiably complicate the voter-registration drives that their clients would be conducting in public places like grocery stores, malls, and parks.

In a 120-page ruling issued on April 24, 2025, Kollar-Kotelly sided with the plaintiffs and granted a Preliminary Injunction blocking Trump’s executive order. She asserted that because the U.S. Constitution delegates control of election regulations to Congress and the various states, the President lacked the authority to issue such an edict unilaterally. “Consistent with that allocation of power, Congress is currently debating legislation that would affect many of the changes the President purports to order,” Kollar-Kotelly wrote in her ruling. “No statutory delegation of authority to the Executive Branch permits the President to short-circuit Congress’s deliberative process by executive order.”

Also in her decision, Kollar-Kotelly wrote that “the proof-of-citizenship directive is an unconstitutional violation of the separation of powers,” and claimed that “on matters related to setting qualifications for voting and regulating federal election procedures,” the Constitution does not assign a “direct role to the President in either domain.”

Moreover, the judge’s ruling also blocked the portion of the same March 25 executive order that required public-assistance enrollees to have their citizenship confirmed before they could fill out a federal voter-registration form.

It should be noted, however, that Kollar-Kotelly’s Preliminary Injunction of April 24 did not entirely reject all of President Trump’s proposed initiatives. For instance, while the judge blocked Trump’s call for a citizenship requirement as a prerequisite for voter registration, she denied the plaintiffs’ request that she also block the President’s call for a mandate stating that all mail-in ballots must be received by election authorities no later than on election day – a requirement that, according to counsel for the Democratic National Committee and other Democratic plaintiffs, would cause “irreparable harm” to the plaintiffs. Further, the judge denied the plaintiffs’ request that she also stop Trump from directing the Departments of Homeland Security and Government Efficiency to compare the names on state voter lists with those in immigration databases.

As a follow up to the April 24 ruling that halted Trump’s proof-of-citizenship order temporarily, on October 31 Kollar-Kotelly issued an 81-page memorandum that made her injunction permanent. Echoing the remarks she had made vis-a-vis her Preliminary Injunction six months earlier, the judge now wrote in her latest opinion:

“Because our Constitution assigns responsibility for election regulation to the States and to Congress, this Court holds that the President lacks the authority to direct such changes…. The Constitution addresses two types of power over federal elections: first, the power to determine who is qualified to vote, and second, the power to regulate federal election procedures. In both spheres, the Constitution vests authority first in the States. In matters of election procedures, the Constitution assigns Congress the power to preempt State regulations. By contrast, the Constitution assigns no direct role to the President in either domain.”

According to an October 31, 2025 report by the Associated Press:

“The ruling [by Kollar-Kotelly] grants the plaintiffs a partial summary judgment that prohibits the proof-of-citizenship requirement from going into effect. It says the U.S. Election Assistance Commission, which has been considering adding the requirement to the federal voter form, is permanently barred from taking action to do so.”

Blocking Trump’s Order Allowing the IRS to Provide Information to ICE

On January 20, 2025, President Trump signed Executive Order 14161, titled “Protecting the United States From Foreign Terrorists and Other National Security and Public Safety Threats.” This Executive Order, coupled with Internal Revenue Code § 6103(i)(2), formed the basis for an April 7, 2025 Memorandum of Understanding (MOU)  by which the Internal Revenue Service (IRS), in a deviation from its previous practices, agreed to provide taxpayer information to the Immigration and Customs Enforcement (ICE) agency for purposes of enforcing non-tax-related criminal and immigration laws. Specifically, this information included the names, addresses and tax years for individuals who were either under criminal investigation by U.S. authorities, or subject to final removal orders.

In response to Trump’s Executive Order, a number of leftwing organizations — such as the Center for Taxpayer Rights, the Main Street Alliance, the National Federation of Federal Employees, and the Communications Workers of America — filed lawsuits against the government.

Presiding over the case was Judge Kollar-Kotelly, who, in a 94-page Memorandum released on November 21, 2025, agreed with the plaintiffs’ assertion that as a result of the Executive Order, immigrants “face an imminent risk that the confidential address information they have provided to the IRS will be impermissibly used by ICE for civil immigration enforcement.” The IRS’s “unlawful conduct,” the judge wrote, was likely to cause the plaintiffs and their members to “suffer irreparable harm.” Consequently, she issued a Preliminary Injunction stating that the IRS’s “arbitrary and capricious” decision to move away from its previous policy of “strict confidentiality” constituted an unlawful violation of the Administrative Procedure Act and Internal Revenue Code privacy protections.

The conclusion of Kollar-Kotell’s November 21 Memorandum reads as follows:

“The Court determines that Plaintiffs have plausibly alleged that the IRS has taken final agency action by changing its policy of strictly protecting confidential taxpayer information and, in its place, implementing a new Data Policy that prioritizes large-scale inter-agency sharing of confidential taxpaye  information. Plaint ffs have also shown a substantial likelihood that at least one specific aspect of the Data Policy—the Address-Sharing Policy—is final agency action. Pursuant to the Data Policy, including the Address-Sharing Policy, the IRS entered into an agreement with ICE to share confidential taxpayer address information and, on August 7, 2025, disclosed address information for approximately 47,000 taxpayers to ICE.

“Plaintiffs have shown a substantial likelihood that both the IRS’s implementation of the Address-Sharing Policy and its subsequent sharing of taxpayer information with ICE were unlawful under the APA [Administrative Procedure Act]. Plaintiffs have shown that the IRS’s implementation of the Address Sharing Policy was arbitrary and capricious because the IRS failed to recognize that it was departing from its prior policy of strict confidentiality, failed to consider the reliance interests that were engendered by its prior policy of strict confidentiality, and failed to provide a reasoned explanation for the new Policy. Furthermore, Plaintiffs have shown that the IRS’s disclosure of confidential taxpayer address information to ICE was contrary to law because it violated several provisions of Internal Revenue Code Section 6103(i)(2). For similar reasons, Plaintiffs have plausibly alleged that the IRS’s broader Data Policy is unlawful under the APA.

“The IRS’s unlawful conduct has created a substantial likelihood that Plaintiffs and their members will suffer irreparable harm. The Center for Taxpayer Rights is experiencing a significant decline in interest and engagement with its core activities of providing pro bono services to low-income taxpayers, including immigrant taxpayers—potentially jeopardizing its federal funding—which it has attempted to mitigate by diverting resources to education and outreach. Plaintiffs’ members, meanwhile, face an imminent risk that their confidential address information will be impermissibly used by ICE for civil immigration enforcement.”

Footnotes:

1. https://ballotpedia.org/Colleen_Kollar-Kotelly
https://www.fjc.gov/node/1383461
https://en.wikipedia.org/wiki/Colleen_Kollar-Kotelly

2. A Pen Register (PR) records dialing or other outgoing signals from a phone or other communications mechanism. Trap and Trace (TT) records all incoming electronic data to a communications device. But PR and TT do not include any record of the content of those communications.

3. The following excerpts, which provide details about the individuals whose deaths have been characterized by various commentators and media outlets as being somehow related to the events of January 6, are from Robert Farley, “How Many Died as a Result of Capitol Riot?” FactCheck.org, November 1, 2021:

• Two heart attacks: According to an April release from the Washington, D.C., medical examiner’s office, “Stop the Steal” protesters Kevin Greeson, 55, and Benjamin Phillips, 50, both died of cardiovascular disease, and the manner of death was deemed “natural.”
• An accidental overdose: D.C. police also said on the day after the riot that Rosanne Boyland, 34, of Kennisaw, Georgia, suffered a “medical emergency.” … [A] month later, the D.C. medical examiner’s office released its conclusion that Boyland had died accidentally of “acute amphetamine intoxication.”
• A stroke victim: A Capitol Police release the day after the riots said that USCP Officer Brian Sicknick “passed away due to injuries sustained while on-duty.” The report stated that Sicknick “was injured while physically engaging with protesters. He returned to his division office and collapsed.” […] But instead, the District of Columbia’s Office of the Chief Medical Examiner [found]  that Officer Brian Sicknick died of natural causes.
• Four suicides: Four other police officers committed suicide in the days and months after the riot. The first was U.S. Capitol Police Officer Howard Liebengood, 51, who had been guarding the Capitol for 15 years and was on duty at the Capitol on Jan. 6. He took his own life three days after the riots. […] Several days later, D.C. Police Officer Jeffrey Smith, 35, who was injured in the riots on Jan. 6, also committed suicide. […] According to People magazine, [Officer] Kyle DeFreytag, 26, was not involved with the clashes with rioters during the breach of the Capitol, but was deployed to the Capitol to help enforce the curfew put in place after the mob had been cleared from the building. [He committed suicide in July 2021.] … The same day the Metropolitan Police Department announced DeFreytag’s death, it confirmed that another officer, Gunther Hashida, had also committed suicide.