International Refugee Assistance Project v. Trump

Filing 67

MOTION by Immigration Law Reform Institute, amicus to file amicus curiae brief (FRAP 29(e)) with consent of all parties on appeal within time allowed by FRAP 29(e).. Date and method of service: 03/31/2017 ecf. [1000053879] [17-1351] Christopher Hajec

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No. 17-1351 ________________________________ United States Court of Appeals for the Fourth Circuit ________________________________ International Refugee Assistance Project, ET AL., Plaintiffs-Appellees, v. Donald J. Trump, ET AL., Defendants-Appellants. ________________________________ On Appeal from the United States District Court for the District of Maryland ________________________________ MOTION BY IMMIGRATION REFORM LAW INSTITUTE TO FILE BRIEF AS AMICUS CURIAE IN SUPPORT OF DEFENDANTS-APPELLANTS AND REVERSAL ________________________________ Christopher J. Hajec Michael M. Hethmon Elizabeth A. Hohenstein Mark S. Venezia IMMIGRATION REFORM LAW INSTITUTE 25 Massachusetts Ave., NW, Suite 335 Washington, DC 20001 Phone: (202) 232-5590 chajec@irli.org mhethmon@irli.org ehohenstein@irli.org mvenezia@irli.org Attorneys for Amicus Curiae The Immigration Reform Law Institute (IRLI) respectfully requests leave to file an amicus curiae brief in support of defendants-appellants and reversal of the decision below. The brief is attached as Exhibit 1 hereto. Amicus curiae the Immigration Reform Law Institute (IRLI) is a non-profit 501(c)(3) public interest law firm dedicated to litigating immigration-related cases on behalf of, and in the interests of, United States citizens and lawful permanent residents, and also to assisting courts in understanding and accurately applying federal immigration law. IRLI has litigated or filed amicus curiae briefs in a wide variety of cases, including Wash. All. of Tech. Workers v. U.S. Dep’t of Homeland Sec., 74 F. Supp. 3d 247 (D.D.C. 2014); Save Jobs USA v. U.S. Dep’t of Homeland Sec., No. 16-5287 (D.C. Cir. filed Sept. 28, 2016); Keller v. City of Fremont, 719 F.3d 931 (8th Cir. 2013); and Texas v. United States, 787 F.3d 733 (5th Cir. 2015). IRLI is considered an expert in immigration law by the Board of Immigration Appeals, which has solicited amicus briefs drafted by IRLI staff for its parent organization, the Federation for American Immigration Reform (FAIR), for more than twenty years. See, e.g., Matter of Silva-Trevino, 26 I. & N. Dec. 99 (B.I.A. 2016); Matter of C-T-L-, 25 I. & N. Dec. 341 (B.I.A. 2010. IRLI proposes to submit its amicus curiae brief to assist this Court in understanding the severe and far-reaching shortcomings of the Establishment Clause holding of the court below, and also how the comprehensive statutory 2 scheme that comprises federal immigration law fully supports the president’s instant exercise of authority. IRLI has often provided similar assistance in understanding this same statutory scheme to the Board of Immigration Appeals, upon specific request by that body, because of IRLI’s unusual expertise in immigration law. See, e.g., Matter of Silva-Trevino, 26 I. & N. Dec. 99 (B.I.A. 2016); Matter of C-T-L-, 25 I. & N. Dec. 341 (B.I.A. 2010); and In re Q- T- -- MT-, 21 I. & N. Dec. 639 (B.I.A. 1996). Accordingly, IRLI is an appropriate amicus curiae in this matter. All parties to this litigation have consented to the filing of the attached brief. DATED: March 31, 2017. \s\ Christopher J. Hajec Christopher J. Hajec Michael M. Hethmon Elizabeth A. Hohenstein Mark S. Venezia IMMIGRATION REFORM LAW INSTITUTE 25 Massachusetts Ave., NW, Suite 335 Washington, DC 20001 Telephone: (202) 232-5590 Fax: (202) 464-3590 chajec@irli.org mhethmon@irli.org ehohenstein@irli.org mvenezia@irli.org Attorneys for Amicus Curiae 3 CERTIFICATE OF SERVICE I certify that on March 31, 2017, the foregoing motion for leave to file an amicus curiae brief was served on all parties or their counsel of record through the CM/ECF system. /s/ Christopher J. Hajec Christopher J. Hajec Attorney for Amicus Curiae 4

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