United States v. California, No. 18-16496 (9th Cir. 2019)
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The United States challenged California's enactment of three laws expressly designed to protect its residents from federal immigration enforcement: AB 450, which requires employers to alert employees before federal immigration inspections; AB 103, which imposes inspection requirements on facilities that house civil immigration detainees; and SB 54, which limits the cooperation between state and local law enforcement and federal immigration authorities.
The Ninth Circuit held that the district court did not abuse its discretion when it concluded that AB 450's employee-notice provisions neither burden the federal government nor conflict with federal activities, and that any obstruction caused by SB 54 is consistent with California's prerogatives under the Tenth Amendment and the anticommandeering rule. Therefore, the panel affirmed the district court's denial of a preliminary injunction as to these laws.
The panel also affirmed the district court's denial of a preliminary injunction as to those provisions of AB 103 that duplicate inspection requirements otherwise mandated under California law. However, the panel held that one subsection of AB 103—codified at California Government Code section 12532(b)(1)(C)—discriminates against and impermissibly burdens the federal government, and so is unlawful under the doctrine of intergovernmental immunity. Therefore, the panel reversed the preliminary injunction order as to this part and remanded for further proceedings.
Court Description: Immigration. In a case in which the United States sought to enjoin the enforcement of three laws California enacted expressly to protect its residents from federal immigration enforcement, the panel affirmed in part and reversed in part the district court’s denial in large part of the United States’ motion for a preliminary injunction. The United States challenged three California laws: AB 450, which—as relevant to this appeal—requires employers to alert employees before federal immigration inspections; AB 103, which imposes inspection requirements on facilities that house civil immigration detainees; and SB 54, which limits the cooperation between state and local law enforcement and federal immigration authorities. The United States sought a preliminary injunction, arguing that these laws violated the doctrine of intergovernmental immunity and the doctrine of conflict preemption. The district court concluded that the United States was unlikely to succeed on the merits of many of its claims, and so denied in large part the motion for a preliminary injunction. With respect to AB 450, which requires employers to alert employees before federal immigration inspections, the panel affirmed the district court’s denial of a preliminary
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