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United States v. California

United States District Court for the Eastern District of California · Constitutional Law

Constitutional LawSupremacy ClausePreemptionTenth AmendmentIntergovernmental ImmunityImmigration Enforcementpreliminary injunctionmandatory injunction

Facts

The United States challenged California laws concerning immigration detention oversight, employer conduct during federal immigration worksite enforcement, and limits on state law-enforcement cooperation with federal immigration authorities. AB 103 required the California Attorney General to inspect and report on certain detention facilities housing noncitizens for civil immigration proceedings. AB 450 prohibited private employers from voluntarily consenting to immigration agents' entry into nonpublic work areas or access to employment records, required notice to employees of I-9 inspections, and barred reverification of employment eligibility except as required by federal law. SB 54 restricted state law-enforcement agencies from sharing certain release-date and address information and from transferring individuals to immigration authorities except in specified circumstances.

Issue

Whether the challenged provisions of AB 103, AB 450, and SB 54 were preempted by federal immigration law or invalid under the doctrine of intergovernmental immunity, such that the United States was entitled to a preliminary injunction. More specifically, the court had to determine where federal immigration authority ends and California's reserved sovereign and police powers begin.

Rule

A federal court may enjoin state law only if the federal government clearly shows entitlement to a mandatory preliminary injunction, including a clear likelihood of success on the merits. In areas of traditional state police power, obstacle preemption requires a clear and manifest congressional purpose, and mere refusal by a State to assist federal enforcement is not itself an obstacle; standing aside is not the same as standing in the way. Under intergovernmental immunity, a State may not directly regulate the Federal Government or discriminate against it or those with whom it deals, including by imposing burdens on private parties because they choose to cooperate with federal operations.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nevada enacted a statute fining private warehouses if they voluntarily allow federal immigration officers into employee-only areas without a judicial warrant. The United States sues in federal court in Reno and seeks a preliminary injunction before the law takes effect, which would halt enforcement of a duly enacted state statute.

What showing must the United States make to obtain that injunction under the governing standard applied here?

Explanation. The court treated an order enjoining enforcement of a state law as a mandatory injunction that alters the status quo. For that reason, the movant had to do more than show ordinary likelihood of success; the law and facts had to clearly favor its position. This rule came from the opinion’s preliminary-injunction analysis, not from any special immigration rule. (Derived from United States v. California (n.d.).)