The family of a father and resident of Chicago, who suffers from traumatic brain injury and paralysis sustained in a drive-by shooting, has sued Immigration and Customs Enforcement (ICE) and the city of Chicago after he was detained on March 27.

Wilmer Catalan-Ramirez was “slammed on the ground” by “six unidentified ICE agents” who “forced entry” into his home “without a warrant or consent,” according to the filed complaint in federal court.

Catalan-Ramirez was taken to McHenry County Adult Correctional Facility, where he is currently being held. The complaint alleges the facility is denying “necessary medical care.”

“I saw the immigration agents slam my husband to the floor while we told them he was injured, but they still hurt him and took him to detention,” recalled Celene Adame.

On January 15, as described in the complaint, Catalan-Ramirez was leaving a restaurant in the Back of the Yards neighborhood as a drive-by shooting occurred. He was hit by multiple bullets, which fractured the right side of his skull and right shoulder.

The shooting left Catalan-Ramirez with a traumatic brain injury as well as partial paralysis in his left side. He suffers from extreme pain in his left shoulder and arm, and he is losing sight in his left eye. He is also losing range of motion on the left side of his body. He spends “most of the day isolated in his cell due to the pain and his inability to safely walk without his left-side ankle brace and proper sneaker footwear.”

He currently requires rehabilitation, including multiple medications daily and physical therapy three times a week. The shooting impaired Catalan-Ramirez’s cognitive abilities, and he “cannot feed, bathe, or dress himself properly without assistance.”

Before he was severely injured on January 17, he was the family’s “primary breadwinner” and worked as a mechanic in a body shop.

The complaint further alleges ICE conducted the raid against Catalan-Ramirez with “false information obtained from the Chicago Police Department’s Gang Database.”

Mark Fleming, who is a litigation coordinator for the National Immigrant Justice Center, has likened this database to the Transportation Security Administration’s No Fly List.

“It seems like it’s a very low standard to get information into that database, and then a very, very high standard to get it out of there,” Fleming told the Chicago Reader. “In fact, there is no current path to getting information out of there.”

Mayor Rahm Emanuel and the City of Chicago claim the city is a “sanctuary city.” Except, the collaboration between CPD and ICE undermines pledges to protect undocumented immigrants.

In fact, as the Reader noted, Chicago police can detain an undocumented immigrant and turn them over to ICE if they are in this “gang database.” (Note: Police may add individuals to this database simply for “wearing red,” etc.)

The lawsuit argues ICE and the City of Chicago violated Catalan-Ramirez’s due process rights as well as his right to protection from unreasonable searches and seizures. It also challenges the “gang database” for its alleged dissemination of “false information about gang membership” in violation of the Illinois Civil Rights Act.

Organized Communities Against Deportations and Mijente, two groups organizing against deportations and harsh immigration enforcement tactics, are supporting Catalan-Ramirez and his family in their lawsuit.

“Wilmer’s case is an example of how local city policies, such as the Gang database, put immigrant communities in the path of Trump’s deportation machine,” said Xanat Sobrevilla, an OCAD organizer. “If the City of Chicago truly wants to be a sanctuary city where immigrants can seek safe refuge, it should stop sharing its Gang Database with ICE and inform ICE the database is rife with inaccuracies and is not a legitimate law enforcement tool.”

Catalan-Ramirez’s wife, Celene Adame, will participate in the May Day demonstrations in Chicago. She is scheduled to speak at one of the rallies.

“There needs to be consequences for everyone responsible for hurting our family, for my husband, and so that it doesn’t happen to others. That’s why today we are here marching and why we are filing the lawsuit” Adame declared.