D.C. Circuit Upholds Block on IRS Sharing Taxpayer Data With ICE, Calls Argument 'Weak Sauce'

A three-judge panel of the U.S. Court of Appeals for the D.C. Circuit — Cornelia Pillard, Patricia Millett, and Robert Wilkins, all Obama appointees — unanimously affirmed on September 8, 2026 a district court's November 2025 preliminary injunction blocking an IRS-ICE data-sharing arrangement. The court found the IRS violated Internal Revenue Code Section 6103(i)(2), a post-Watergate tax-confidentiality safeguard requiring the requesting agency to already know a taxpayer's address before the IRS discloses related records; ICE instead submitted only a five- or nine-digit placeholder in the address field to obtain the last known addresses of 1.28 million people it said were unlawfully present. The IRS had disclosed roughly 47,000 taxpayer addresses under the arrangement before being stopped, which a district judge found violated the statute approximately 42,695 times. Judge Pillard wrote that the IRS is 'now on notice twice over regarding the legal inadequacies of its summer 2025 disclosures' and warned of 'steep civil and criminal consequences' for willful violations, while the panel separately dismissed the administration's defense of the arrangement as 'weak sauce' and said any complaint about the underlying statute's limits belonged before Congress. The ruling keeps the injunction in place; no Supreme Court appeal has been announced.