Intl. Refugee Assistance v. Donald J. Trump

Filing 101

AMICUS CURIAE BRIEF by BENNA RUTH SOLOMON, Attorney for amicus curiae City of Chicago in electronic and paper format. Method of Filing Paper Copies: mail. Date Paper Copies Mailed, Dispatched, or Delivered to Court: 11/20/2017. [1000194735] [17-2231, 17-2232, 17-2233, 17-2240] Benna Solomon [Entered: 11/17/2017 04:49 PM]

Download PDF
___________________________________________________ APPENDIX ___________________________________________________ CHICAGO The population of the City of Chicago is 2,717,534.20 Chicago has residents from more than 127 foreign countries.21 At least 572,066 of our residents are immigrants.22 Approximately 5,600 of Chicago’s residents were born in Chad, Iran, Libya, Somalia, Syria, and Yemen.23 Approximately 1.27 million people are employed in Chicago.24 Of those, 26.5% are foreign-born immigrants,25 including an estimated 976 noncitizen immigrants from the six targeted countries.26 The City of Chicago itself employs more than 32,000 people.27 Approximately 27% of Chicago’s business owners are immigrants,28 of whom an estimated 0.7% come from the six targeted countries.29 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 21 Id. 22 Id. 23 U.S. Census Bureau, American Community Survey PUMS 1-Year 2016 Data. 24 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 25 Id. 26 Id. 27 current_employeenames%salariesandpositiontitles.html 28 29 Id. 20 A2 At least 12,500 private employees work in Chicago on international visas.30 In 2016, approximately 2,091 refugees were resettled in our city, including 764 from the six targeted Muslim-majority countries.31 Chicago has 34 four-year colleges and universities, and these have more than 13,789 international students in the 2015-16 academic year.32 City Colleges of Chicago (CCC) has 7 colleges, and these had approximately 338 international students in the 2016-17 academic year. Of these, 145 CCC students were born in, arrived on visas from, or are nationals of the six countries.33 The tourism sector of Chicago’s local economy accounts for $911 million a year in local tax revenue and $2.3 billion in hotel revenue alone.34 On any given day, 232 flights arrive at Chicago airports from international destinations, bringing 31,856 passengers.35 Each international flight arrival yields approximately $212,000 in local economic impact.36 (by destination and nationality). U.S. Department of State, Bureau of Population, Refugees and Migration, Office of Admissions – Refugee Processing Center, available at 32; 33 Jeff Donoghue, CCC (includes Credit students only). 34 Alfred Orendorff (ChooseChicago). 35 Facts and Figures/Air Traffic Data/1216%ORD%SUMMARY.pdf. 36 Jonathan Leach, Chicago Department of Aviation. 30 31 A3 In 2016, Chicago welcomed 54.1 million visitors,37 1.62 million of whom visited from overseas.38 Approximately 1000 international visitors were from the six targeted countries.39 In 2015, tourism brought $14.66 billion in direct spending to Chicago. Spending by international visitors to Chicago is estimated at $1.88 billion per year. This generates $112 million in state and local tax revenues annually.40 The average overseas visitor spends about $2,313 per trip while visiting Chicago.41 Tourists from the six countries account for an estimated $1.25 million of local economic impact per year.42 Chicago is home to 44 major hospitals,43 which serve thousands of international patients a year, and the Middle East is the top source of patients traveling to the U.S. for medical care.44 press_releases/2016/april/Mayor-Choose-Chicago-Announce-RecordTourism-2015.html. 38 U.S. Department of Commerce, National Travel and Tourism Office, 2015_States_and_Cities.pdf. 39 Alfred Orendorff (ChooseChicago). 40 Id. 41 Id. 42 Id. 43; h/Find_a_clinic.html. 44 170209996/how-trumps-travel-ban-could-hit-medical-tourism-hard. 37 A4 The City of Chicago established the Chicago Legal Protection Fund (“the Fund”) to increase legal services for immigrant communities across the city.45 $1.3 million has been allocated to the Fund for FY2017 to support organizations – including Heartland Alliance’s National Immigrant Justice Center (NIJC) and the Resurrection Project (TRP) – that will serve more than 20,000 immigrants through community-based outreach, education, legal consultations, and legal representation, including courtroom representation.46 NIJC also received $150,000 from the City of Chicago for FY2017 for its Immigrant Children’s Protection Project, which provides legal services to unaccompanied children held in Chicago-area shelters.47 In calendar year 2016, NIJC and TRP represented clients from at least 132 countries, including clients from each of the six targeted countries.48 In Chicago, there were twice as many arrests for hate crimes in the three months after the election than during the same period in the prior year.49 In the first five weeks of 2017, the number of hate crimes recorded in Chicago was more than triple the number for the same period in 2016. Additionally, hate crimes categorized as anti-Muslim or anti-Arab hit five-year highs in Chicago in 2016.50 Seemi Choudry, Director of Office of New Americans, City of Chicago. Id. 47 Id. 48 Id. 49 Brandon Nemec, Mayor’s Office liaison with Chicago Police Department. 50 Zak Koeske, Hate crimes in Chicago rose 20 percent in 2016, marking 5-year high, police data show, Chicago Tribune (Mar. 3, 2017). 45 46 A5 NEW YORK CITY The population of New York City is 8,537,673 as of 2016.51 We have residents from more than 150 foreign countries.52 New York City is home to over 3 million foreign-born New Yorkers, about 37% of the City’s population. Approximately 49% of New Yorkers speak a language other than English at home.53 New York City is home to an estimated 33,792 individuals born in Chad, Yemen, Syria, Iran, Somalia, and Libya.54 Approximately 4.1 million people are employed in New York City; of those, 46% are foreign-born immigrants.55 New York City itself employs 287,000 people,56 34% of them foreign-born.57 51% of New York City’s business owners are immigrants.58 About 1,300 refugees have been resettled in New York City between October 1, 2012 and September 30, 2017, according to federal data.59 76 refugees from the targeted countries resettled in the city in 2016 alone. U.S. Census Bureau, 2016 American Community Survey 1-Year Estimates. 52 Id. 53 Id. 54 Id. 55 Id. 56 57 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 58 Our Immigrant Population Helps Power NYC Economy, Comptroller Scott Stringer, 2017. 51 A6 The tourism sector of New York City’s local economy includes direct visitor spending in 2016 of $43 billion.60 In 2016, New York City welcomed 60.5 million visitors, including 12.7 million foreign visitors.61 New York City has 87 four-year colleges and universities, and these have approximately 47,000 international students.62 In the six months following the President’s first travel ban executive order in January, NYPD Hate Crime Task Force data show 215 incidents of bias crime have occurred in the city. This is an increase of 31% when compared to the same timeframe last year.63 U.S. Department of State, Bureau of Population, Refugees, and Migrants Office of Admissions—Refugee Processing Center. 60 61 Id. 62 63 NYPD data through July 31, 2017. 59 A7 LOS ANGELES The population of our metropolitan area (Los Angeles County) is 10.2 million people, with more than 3.9 million living within the city limits.64 We have residents from more than 135 foreign countries, and 185 languages are spoken here.65 At least 1.5 million of our city’s residents are themselves immigrants, 37.8% of our total population. Approximately 43% of all residents of Los Angeles County were born in another country.66 As of 2015, the Los Angeles metropolitan area had over 152,000 immigrants from the six affected countries, including 136,000 from Iran, 14,900 from Syria, 500 from Somalia, and 100 from Yemen. 67 Our city employs approximately 45,000 people, 22% of whom are foreign-born immigrants. 44% of business owners in Los Angeles are immigrants.68 In 2016, approximately 2,322 refugees were resettled in Los Angeles County, including approximately 1,936 from the six targeted countries, and 1,808 from Iran alone.69 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 65 Id. 66 Id. 67 68 2010 ACS Single year estimate. 69 U.S. Department of State, Bureau of Population, Refugees and Migration, Office of Admissions – Refugee Processing Center. 64 A8 On any given day, 185 flights arrive at LAX from international destinations bringing 31,000 passengers, including more than 150 from the targeted countries.70 The tourism sector of the local economy accounts for $21 billion a year in direct spending by visitors to Los Angeles County and $260 million in hotel taxes alone. Tourism supports approximately 500,000 jobs in the leisure and hospitality sectors.71 In 2016, Los Angeles welcomed 47 million visitors, 7.1 million of whom were foreign nationals who spent a combined $6.3 billion. At least 160,000 of those visitors hail from the Middle East, and they spent at least $185 million while in Los Angeles.72 Los Angeles has at least ten four-year colleges and universities, and these have approximately 25,000 international students.73 The Mayor of Los Angeles has reported that hate crime incidents doubled following the presidential election, with 30 such reported incidents during the month following.74 LAX officials. 71 Discover LA. 72 Id. 73 University enrollment data. 74 70 A9 CITY OF PHILADELPHIA The population of the City of Philadelphia is approximately 1,526,006,75 and for the Philadelphia Metropolitan Statistical Area, the estimated population is 6,051,170.76 Philadelphia has residents from more than 130 foreign countries.77 At least 197,563 of our residents are immigrants.78 Approximately 830 of Philadelphia residents were born in Chad, Iran, Libya, Somalia, Syria, and Yemen.79 Approximately 640,661 people are employed in Philadelphia, and 108,010 of them are foreign-born, a figure that does not include individuals who work in Philadelphia but reside outside the city.80 In 2013, immigrants made up 14% of business owners in Philadelphia; and immigrants are 28% of the area’s “Main Street” business owners, including 23% of retail store owners and 34% of restaurant owners.81 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 76 U.S. Census Bureau, Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2014 – United States – Metropolitan and Micropolitan. 77 U.S. Census Bureau, Place of Birth for the Foreign-Born Population in the United States, 2011-2015 American Community Survey 5-year Estimates. 78 Id. 79 Id. 80 U.S. Census Bureau, Selected Characteristics of the Native and Foreign-Born Populations, 2011-2015 American Community Survey 5Year Estimates. 75 A10 In 2016, approximately 794 refugees were resettled in Philadelphia, including 253 from the six targeted countries.82 The Philadelphia Metropolitan Area is home to 31 four-year colleges and universities, whose students include 21,273 international students.83 The economic impact from tourism in the City of Philadelphia in 2015 was $6.2 billion, including $3.9 billion in direct visitor spending, and that tourism generated an estimated $277 million in tax revenues for the City of Philadelphia.84 Americas Society/Council of the Americas and Fiscal Policy Institute, Bringing Vitality to Main Street: How Immigrant Small Businesses Help Local Economies Grow, at 16 (available at 82 U.S. Department of State, Bureau of Population, Refugees and Migration, Office of Admissions – Refugee Processing Center. Available at 83 CampusPhilly; Christine Farrugia, Rajika Bhandari, Ph.D., 2015 Open Doors, Report on International Educational Exchange. 84 Philadelphia Convention and Visitors Bureau (Staff Person), citing Tourism as an Economic Engine for Greater Philadelphia 2015 Visitation and Economic Impact Report, available at 81 A11 In the 3 months immediately after the November 2016 election (11/1601/17), 11 hate crimes were reported to Philadelphia police. In the 3month period around the same time last year (11/15-01/16), 7 hate crimes were reported, a 157% increase.85 In the same time period, the Philadelphia Commission on Human Relations received reports of 43 separate hate or bias incidents, as compared to just 3 reports during the same time last year, a 1433% increase.86 In just the first eight months of 2017, Philadelphia has already received 30 reports of hate crimes, approximately double the number received in each of the preceding five years.87 Philadelphia Police Department, Research and Analysis Unit Statistical Section; see also Uniform Crime Reporting System, Monthly Summary Hate / Bias Motivation Report for Philadelphia City, available at Summary/MonthlySumHateUI.asp?rbSet=4. 86 Philadelphia Commission on Human Relations; see also 87 MonthlySumHateUI.asp. 85 A12

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?