Intl. Refugee Assistance v. Donald J. Trump
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.  [17-2231, 17-2232, 17-2233, 17-2240] Benna Solomon [Entered: 11/17/2017 04:49 PM]
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
23 U.S. Census Bureau, American Community Survey PUMS 1-Year
24 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year
At least 12,500 private employees work in Chicago on international
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
http://ireports.wrapsnet.org/ (by destination and nationality).
U.S. Department of State, Bureau of Population, Refugees and
Migration, Office of Admissions – Refugee Processing Center, available
32 http://www.collegesimply.com/colleges/illinois/chicago/four-yearcolleges/; http://www.iie.org/Research-and-Publications/OpenDoors/Data/Fact-Sheets-by-US-State/2016%-%.WJe7MrYrJTY.
33 Jeff Donoghue, CCC (includes Credit students only).
34 Alfred Orendorff (ChooseChicago).
Facts and Figures/Air Traffic Data/1216%ORD%SUMMARY.pdf.
36 Jonathan Leach, Chicago Department of Aviation.
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
The average overseas visitor spends about $2,313 per trip while visiting
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
38 U.S. Department of Commerce, National Travel and Tourism Office,
39 Alfred Orendorff (ChooseChicago).
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
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
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.
49 Brandon Nemec, Mayor’s Office liaison with Chicago Police
50 Zak Koeske, Hate crimes in Chicago rose 20 percent in 2016, marking
5-year high, police data show, Chicago Tribune (Mar. 3, 2017).
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
57 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year
58 Our Immigrant Population Helps Power NYC Economy, Comptroller
Scott Stringer, 2017.
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.
63 NYPD data through July 31, 2017.
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
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
68 2010 ACS Single year estimate.
69 U.S. Department of State, Bureau of Population, Refugees and
Migration, Office of Admissions – Refugee Processing Center.
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
71 Discover LA.
73 University enrollment data.
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
76 U.S. Census Bureau, Annual Estimates of the Resident Population:
April 1, 2010 to July 1, 2014 – United States – Metropolitan and
77 U.S. Census Bureau, Place of Birth for the Foreign-Born Population
in the United States, 2011-2015 American Community Survey 5-year
80 U.S. Census Bureau, Selected Characteristics of the Native and
Foreign-Born Populations, 2011-2015 American Community Survey 5Year Estimates.
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
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 http://www.ascoa.org/sites/default/files/ImmigrantBusinessReport.pdf).
82 U.S. Department of State, Bureau of Population, Refugees and
Migration, Office of Admissions – Refugee Processing Center. Available
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
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
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 http://ucr.psp.state.pa.us/UCR/Reporting/Monthly/
86 Philadelphia Commission on Human Relations; see also
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