United States of America v. State of California et al

Filing 116

MOTION for LEAVE to FILE AMICI CURIAE BRIEF by National Immigration Law Center (and associated parties). Attorney Weissglass, Jonathan D added. Motion Hearing set for 6/20/2018 at 10:00 AM before District Judge John A. Mendez. (Attachments: # 1 Proposed Amicus Brief, # 2 Proposed Order)(Weissglass, Jonathan) Modified on 5/21/2018 (Benson, A.).

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Jonathan Weissglass (SBN 185008)
Law Office of Jonathan Weissglass
410 12th Street, Suite 250-B
Oakland, CA 94607
Telephone: [phone]
E-mail: [e-mail]
Nicholas Espíritu* (SBN 237665)
Jana Whalley* (SBN 318367)
National Immigration Law Center
3450 Wilshire Boulevard, #108-62
Los Angeles, CA 90010
Telephone: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Amici Curiae
*Application for admission forthcoming

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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THE UNITED STATES OF AMERICA,

Case No. 18-cv-00490-JAM-KJN

Plaintiff,

UNOPPOSED MOTION OF
NATIONAL IMMIGRATION LAW
v.
CENTER AND 79 OTHER
ORGANIZATIONS FOR LEAVE TO
THE STATE OF CALIFORNIA; EDMUND
FILE BRIEF AS AMICI CURIAE IN
GERALD BROWN JR., Governor of California, SUPPORT OF DEFENDANTS’
in his Official Capacity; and XAVIER
OPPOSITION TO PLAINTIFF’S
BECERRA, Attorney General of California, in
MOTION FOR A PRELIMINARY
his Official Capacity,
INJUNCTION
Defendants.

Date: June 20, 2018
Time: 10:00 a.m.
Judge: Hon. John A. Mendez

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MOTION OF NILC, ET AL., FOR LEAVE TO FILE BRIEF AS AMICI CURIAE
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Pursuant to the Court’s Orders of March 27 and March 29, 2018 (Docket Nos. 37, 41),

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the National Immigration Law Center and 79 other organizations seek leave to file a brief as

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amici curiae. All parties have consented to the brief being filed.

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The amici organizations advocate for the rights of immigrants and their families and

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work on related issues. In the attached brief, amici go beyond California’s showing of why the

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Court should deny the federal government’s request for a preliminary injunction against portions

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of three California laws – SB 54, AB 450, and AB 103. Part I of this brief uses experiences,

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stories, and reports to demonstrate why the public interest supports the three laws, and in

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particular how the laws advance public safety, prevent the mistreatment of undocumented

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individuals, protect workers and workplace standards, and protect the health and safety of

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immigrant detainees. Part II of the brief addresses legislation in state and local jurisdictions

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outside of California, and shows that the ramifications of this Court’s decision will extend

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nationwide.

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Amici bring significant expertise and interest to the case. The following briefly describes
each organization:

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The National Immigration Law Center (“NILC”) is the primary national organization in

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the United States exclusively dedicated to defending and advancing the rights and opportunities

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of low-income immigrants and their families. Over the past 35 years, NILC has won landmark

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legal decisions protecting fundamental rights, and has advanced policies that reinforce the values

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of equality, opportunity, and justice. A major concern of the organization has been federal

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preemption and state and local authority to adopt policies that promote the wellbeing and sense

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of inclusion of all community members.

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The California Immigrant Policy Center (“Policy Center”) is the premiere immigrant

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rights institution in the state that promotes and protects safety, health and public benefits and

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integration programs for immigrants, and one of the few organizations that effectively combines

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legislative and policy advocacy, strategy communications, organizing and capacity building to

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pursue its mission. The organization has championed local and statewide efforts to disentangle

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local police from the deportation system, helping to secure passage of the TRUST, TRUTH, and
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CA Values Acts, and is committed to building upon and expanding these protections. The Policy

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Center is a constituent-based statewide immigrant rights organization with member organizations

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that work with directly impacted communities across the state.

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The Alabama Coalition for Immigrant Justice is a grassroots, statewide network of

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individuals and organizations that works to advance and defend the rights of immigrants in

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Alabama. The coalition consists of six non-profit organizations, 14 grassroots immigrant

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community organizations, and hundreds of individual members. The coalition is leading

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Alabama to a more equitable and just multi-ethnic, multi-lingual future – building a better

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Alabama for everyone, from the ground up.

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Alliance San Diego works to empower diverse people and organizations to engage more

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effectively in our communities and civic process to create a San Diego where all people can

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achieve their full potential in an environment of harmony, safety, equality and justice. Alliance

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San Diego stands in strong support of the California Values Act.

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The American-Arab Anti-Discrimination Committee (“ADC”) is a nonprofit, grassroots

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civil rights organization committed to defending the rights of people of Arab descent and

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promoting their rich cultural heritage. Founded in 1980 by U.S. Senator James Abourezk, ADC

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is non-sectarian and non-partisan. With members from all fifty states and chapters nationwide,

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ADC is the largest Arab-American grassroots civil rights organization in the United States.

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ADC protects the Arab-American and immigrant community against discrimination, racism, and

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stereotyping, and it vigorously advocates for immigrant rights and civil rights. ADC’s

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immigration policy work focuses on counteracting the criminalization of immigrants and law

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enforcement activities that target immigrant populations.

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Americans for Immigrant Justice (“AIJ”) is a non-profit law firm dedicated to promoting

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and protecting the basic rights of immigrants. Since its founding in 1996, AIJ has served over

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100,000 immigrants from all over the world. Its clients are unaccompanied immigrant children;

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survivors of domestic violence, sexual assault, and human trafficking and their children;

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immigrants who are detained and facing removal proceedings; as well as immigrants seeking

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assistance with work permits, legal permanent residence, asylum, and citizenship. Part of AIJ’s
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mission is to ensure that immigrants are treated justly, and to help bring about a society in which

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the contributions of immigrants are valued and encouraged. In Florida and on a national level,

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AIJ champions the rights of immigrants, serves as a watchdog on immigration detention

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practices and policies, and speaks for immigrants with compelling claims to justice.

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The Arizona Dream Act Coalition (“ADAC”) is an immigrant youth led organization in

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Phoenix. It is the mission of ADAC to advocate for the rights of undocumented immigrant

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communities by fostering leadership, and promoting civic engagement and access to higher

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education for immigrant youth. ADAC provides services that advance the integration of

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immigrant youth and their families through values of equity, opportunity, and justice.

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Asian Services In Action, Inc. (“ASIA”) was founded in 1995 by four women who

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sought to improve the quality of life for Asians in Northeast Ohio. ASIA’s mission is to

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empower and advocate for Asian Americans and Pacific Islanders; and to provide them and other

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communities access to quality culturally and linguistically appropriate information, health, and

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social services. Serving as the only Asian American and Pacific Islander focused health and

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social services 501(c)(3) organization in the State of Ohio, ASIA has taken on the most

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challenging tasks to help the underserved, low-income and immigrant communities across the

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state. ASIA is invested in ensuring the safety and well-being of local communities from federal

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government overreach in breaking up families and targeting immigrants.

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The Asian American Legal Defense and Education Fund (“AALDEF”), founded in 1974,

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is a national organization that protects and promotes the civil rights of Asian Americans. By

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combining litigation, advocacy, education, and organizing, AALDEF works with Asian

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American communities across the country to secure human rights for all. The rights of

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immigrants in this country are central to AALDEF’s mission.

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The Asian Law Alliance (“ALA”) is a non-profit law office founded in 1977 by law

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students from Santa Clara University School of Law. ALA’s mission is to provide equal access

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to the justice system to Asian and Pacific Islanders and low-income residents of Santa Clara

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County. ALA provides legal services in the areas of public benefits, civil rights, domestic

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violence, landlord and tenant law, and immigration law. Asian Law Alliance has advocated for

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the rights of immigrants for more than 41 years.

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Bet Tzedek – Hebrew for the “House of Justice” – was established in 1974 and provides

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free legal services to Los Angeles County residents. Bet Tzedek’s Employment Rights Project

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assists low wage and immigrant workers through a combination of individual representation

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before the California Labor Commissioner, litigation, legislative advocacy, and community

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education. Bet Tzedek has taken a leading role in advocating for the rights of immigrant workers

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in California, including by submitting amicus briefs and letters on such issues of broad

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importance to California employees as those presented in the instant case.

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The California Employment Lawyers Association (“CELA”) is an organization of over

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1,300 California attorneys whose members primarily represent employees in a wide range of

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employment cases, including individual, class actions, and representative actions to enforce

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California’s employment laws and ensure the vindication of the public policies embodied in

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California employment law. CELA members also recommend, draft, edit, and support

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legislation which benefits working men and women. In the experience of CELA’s membership,

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a large portion of law-wage workers in California is comprised of immigrants or those perceived

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to be immigrants. Such workers have little bargaining power in the employment relationship and

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are thus susceptible to intimidation, threats, and retaliation should they pursue their legal rights

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in the workplace.

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Canal Alliance is a Marin County, California, nonprofit champion of immigrants who are

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challenged by a lack of resources and an unfamiliar environment. Canal Alliance’s goal is to

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break the cycle of poverty, by offering immigration services, family services, and various

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education programs. Canal Alliance serves a mainly Latino low-income population. Canal

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Alliance has been around for over 30 years fighting and advocating for its community.

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CASA is the foremost Latino and immigrant organization in the mid-Atlantic region and

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a national leader in supporting immigrant families and ensuring that all individuals have the core

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supports necessary for full participation in society. CASA was founded in 1985 and its mission

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is to create a more just society by building power and improving the quality of life in working
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class and immigrant communities. Over its 32-year history, CASA has won the deep trust of the

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immigrant community and established itself as a strong national leader in innovations for

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immigrant-focused services, as well as a backbone organization for collective impact involving

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community-based, government, and private partners. A core part of CASA’s work is

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encouraging state and local governments to build trust with their immigrant residents and enact

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policies that ensure family unity and prosperity for all, free from federal overreach and

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interference.

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Catholic Charities of Oregon Immigration Legal Services provides legal services to lowincome immigrants throughout the state of Oregon. A major part of its practice includes

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providing services to immigrants who are victims of crime. Laws such as California’s SB 54 and

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similar legislation in Oregon encourage immigrant crime victims to get needed help from law

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enforcement and facilitate the protection of their rights.

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Causa is Oregon’s Latino immigrant rights organization. Causa was founded in 1995 by

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farmworkers, Latinos, immigrants, and allies to defeat ballot measures that would have

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negatively impacted the lives of Latino families in Oregon. Causa works at the state and national

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levels to advance issues that impact the daily lives of Latino immigrant families. Some of these

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issues include immigration reform, driver licenses, access to higher education, economic justice,

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and health equity. A primary concern of Causa is the preservation of common sense protections

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for immigrant workers and families.

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Center for Employment Training Immigration and Citizenship Program (“CET-ICP”)

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provides high quality immigration and citizenship services in Santa Clara County and beyond,

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and promotes and strengthens civic involvement among the immigrant population. CET-ICP

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supports local policies that promote the safety, inclusion and empowerment of all community

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members.

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The Center for Popular Democracy is a national organization that works to advance

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progressive policy change on a wide range of issues through grassroots organizing and advocacy.

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Since its founding, the organization has fought for the equal rights of non-citizens, and has led

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campaigns in over 20 cities, counties, and states to enact laws and policies that will mitigate the
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impact of mass deportation on immigrant communities. The legal grounding for many of the

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victories the organization has won is at issue in this case, and the stakes for its grassroots

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affiliates in this litigation are extremely high.

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The Central Coast Alliance United for a Sustainable Economy (“CAUSE”) dedicates

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itself to building grassroots power to advance social, economic, and environmental justice for

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people of California’s Central Coast Region. CAUSE has a vision that together we can create a

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global community where we all contribute to, and benefit from, a sustainable economy that is

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just, prosperous, and environmentally healthy. For this reason, CAUSE supports states and

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localities adopting policies that benefit and include all community members.

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The Central Coast Immigrant Rights Coalition (“CCIRC”) unites organizations to

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educate and organize immigrants and allies, and to advocate for humane and just policies that

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advance the rights of all immigrants. CCIRC envisions a central coast region in which

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immigrants are self-empowered, celebrated, safe from the fear of criminalization, raids, and

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deportation, and are fully afforded the rights and responsibilities of civic sustainable policies that

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uphold the human rights of immigrants.

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The Central Valley Immigrant Integration Collaborative (“CVIIC”) serves as the leading

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immigrant integration organization in the Central Valley, dedicated to ensuring full participation

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of immigrants in building strong, vibrant, inclusive communities. CVIIC’s priorities include

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support for policies that uphold the American tradition of being a nation of immigrants, promote

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the full (economic, social, civic) integration of immigrant families, and ensure due process.

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Centro de los Derechos del Migrante, Inc. (“CDM” or the “Center for Migrant Rights”) is

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a U.S. section 501(c)(3) migrant workers’ rights organization with offices in Baltimore,

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Maryland; Mexico City; and Oaxaca, Mexico. CDM’s mission is to improve the working

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conditions of low-wage workers throughout the U.S. and to ensure the U.S.-Mexico border is not

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a barrier to access to justice. The foreign-born communities CDM serves are frequently

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subjected to labor, civil rights, and constitutional violations. CDM therefore has a significant

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interest in preserving the protections provided under the California laws at issue in this case.

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Centro Laboral de Graton organizes with day laborers and domestic workers for their

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rights and dignity as workers and immigrants. The organization’s mission is to advance and

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protect the human, labor, and civil rights of day laborers, domestic workers, and their families by

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promoting participatory democratic leadership and worker solidarity, to develop greater

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opportunities for employment, health, education, and civic participation.

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Centro Legal de la Raza (“Centro Legal”), founded in 1969, is a comprehensive legal

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services agency protecting and advancing the rights of immigrant, low-income, and Latino

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communities through bilingual legal representation, education, and advocacy. By combining

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quality legal services with know-your-rights education and youth development, Centro Legal

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promotes access to justice for thousands of individuals and families each year throughout

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Northern and Central California. The three California laws at stake in this case are critical to

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promoting the well-being and security of the communities Centro Legal serves.

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The Coalition for Humane Immigrant Rights (“CHIRLA”) is a nonprofit organization

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whose mission is to create a just society fully inclusive of immigrants. CHIRLA organizes

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thousands of immigrants and their families to engage in programs that include organizing, legal

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services, civic engagement, and policy advocacy.

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Communities for a Better Environment (“CBE”) is an environmental justice organization

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that provides community organizing, and technical and legal support to low-income communities

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of color in the Los Angeles and Bay areas. Established in 1978 in California, CBE works to

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empower communities, including immigrant communities, to exercise their rights around social

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change. CBE’s members rely on California’s protections so they can safely advocate for a

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healthy environment where they live, work, play, and pray.

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Community Legal Services in East Palo Alto (“CLSEPA”) provides transformative legal

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services to low-income immigrants in and around East Palo Alto, California, where two-thirds of

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the population is Latino or Pacific Islander. CLSEPA’s practice areas include immigration,

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housing, and economic advancement. It recently established an Immigrants’ Rights Project in

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part to ensure that the constitutional rights of immigrants are upheld through litigation and policy

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advocacy, and to secure and protect immigrant friendly policies.
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The Council on American-Islamic Relations, California (CAIR-CA), is a chapter of the

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nation’s largest American Muslim civil rights and advocacy organization. CAIR-CA’s mission

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is to enhance understanding of Islam, protect civil rights, promote justice, and empower

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American Muslims. As part of its legal services efforts, CAIR-CA provides immigration legal

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services through each of its four local offices, working to empower and protect non-citizens.

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CAIR-CA is dedicated to providing services to individuals whose immigration status and daily

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lives will be impacted by the injunction the federal government seeks.

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Dolores Street Community Services (“DSCS”) nurtures individual wellness and
cultivates collective power among low-income and immigrant communities to create a more just

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society. DSCS’s Deportation Defense and Legal Advocacy Program provides legal services to

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immigrants in San Francisco, specializing in complex removal defense cases and particularly

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vulnerable clients, including those in immigration detention and immigrant survivors of crime.

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DSCS’s Workers’ Rights programs focus on uniting, empowering, and organizing immigrant

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workers for dignified work and fair wages. As an organization, DSCS has witnessed the toll

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taken by local law enforcement’s entanglement with federal immigration enforcement, and has

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been particularly concerned about the conditions in which its detained clients are held.

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Esperanza Community Housing Corporation (“Esperanza”) is a social justice non-profit

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dedicated to the equitable development and the protection of human rights in South Central Los

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Angeles. Low-income residents of all ages and backgrounds are the foundation of Esperanza’s

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grassroots work. Esperanza creates opportunities for growth, security, inclusion, and

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participation. Esperanza develops and preserves affordable housing; promotes health equity and

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access to care; celebrates involvement in the arts and culture; pursues economic development;

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ensures inclusion for all residents; and advocates for progressive public policy and human rights.

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Esperanza believes that all community members have a right to live in an environment that

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protects their individual and collective safety; prevents mistreatment of individuals based on

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their perceived ethnicity, and resulting from xenophobia and racial profiling; and protects their

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health and well-being, regardless of their circumstances.

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GLBTQ Legal Advocates & Defenders (“GLAD”), through strategic litigation, public

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policy advocacy, and education, works in New England and nationally to create a just society

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free of discrimination based on gender identity and expression, HIV status, and sexual

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orientation. GLAD has litigated widely in both state and federal courts in all areas of the law to

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protect and advance the rights of lesbians, gay men, bisexuals, transgender individuals, and

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people living with HIV and AIDS. GLAD has an enduring interest in ensuring that our

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government treats every individual in this country equally and with dignity and respect.

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The Illinois Coalition for Immigrant and Refugee Rights (“ICIRR”) is dedicated to

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promoting the rights of immigrants and refugees to full and equal participation in the civic,

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cultural, social, and political life of our diverse society. In partnership with member

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organizations, the Coalition educates and organizes immigrant and refugee communities to assert

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their rights; promotes citizenship and civic participation; monitors, analyzes, and advocates on

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immigrant-related issues; and, informs the general public about the contributions of immigrants

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and refugees. ICIRR has successfully advocated for state and local policies that respect

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immigrants and support their ability to seek police protection, education, health care, and other

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services, and has opposed policies (including expansion of immigration detention) that seek to

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separate immigrant families and undermine immigrant communities.

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Immigrant Defenders Law Center (“ImmDef”) is an independent, non-profit law firm

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dedicated to advancing social justice for Southern California’s most marginalized immigrant

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communities through legal services, community empowerment, and advocacy for adults and

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children in federal immigration custody. ImmDef strives to ensure every noncitizen in removal

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proceedings is guaranteed due process through access to counsel. Through its representation

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programs, ImmDef provides pro bono representation to over 700 immigrants in deportation

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proceedings. To ensure due process, ImmDef’s present and future clients will benefit from the

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protection of California laws that can protect them and their families from indiscriminate and

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inhumane immigration enforcement actions.

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The Immigration Center for Women and Children (“ICWC”) is a state-wide organization

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in California dedicated to providing affordable immigration services to children who are abused,
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abandoned, or neglected, and for immigrants who are victims of domestic violence, sexual

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assault, and other violent crimes. Over the past 14 years, ICWC has provided security and

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stability to immigrants seeking a safer path forward. ICWC helps an average of 1,000 crime

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victims annually apply for the U visa, which is immigration relief for victims of crime who have

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cooperated with law enforcement. Our communities are safer when California laws can protect

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immigrants’ ability to live, work, and report crime to law enforcement.

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The Innovation Law Lab (“the Law Lab”) is a nonprofit organization established to

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promote, improve, and strengthen due process rights for immigrants and their communities. The

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Law Lab uses empirical analysis, technology, and litigation to ensure the fair and just

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administration of our laws. The Law Lab has a direct interest in promoting rule-of-law

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principles in federal immigration enforcement and in furthering local efforts to promote

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immigrant-inclusive resolutions and policies.

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The International Service Center (“ISC”) is a community-based nonprofit organization

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established in 1976 for the purpose of promoting, supporting, and implementing educational,

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cultural, social, and economic development programs to serve the disadvantaged and

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underprivileged people, to enable them to become self-supporting and productive members of

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our society. Over the past 42 years, ISC has been providing a variety of essential services and

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needed opportunities to newly arrived refugees and immigrants to help them successfully

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integrate in their new homeland.

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The Korean Resource Center (“KRC”) is a non-profit community organization

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empowering low-income, immigrants, Asian American and Pacific Islander, and people of color

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communities in Southern California. Using a holistic approach, KRC integrates services,

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education, culture, organizing, and coalition building. KRC stands with the immigrant

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community and support the efforts of state and local authorities to embrace policies that protect

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and includes all community members.

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La Raza Centro Legal is a multicultural public interest law and social justice center that

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was founded in 1973 and is based in the Mission District of San Francisco. Its mission is to

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create a more just and inclusive society in the interests of the Latino, indigenous, immigrant and
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low-income people of San Francisco and the greater Bay Area. Through its programs in legal

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services and community empowerment, the organization seeks to enable people to know and

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exercise their own legal rights, confront injustice, increase self-sufficiency, and advocate for

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themselves.

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LatinoJustice PRLDEF (“LatinoJustice”), founded in 1972 as the Puerto Rican Legal

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Defense and Education Fund, champions an equitable society. Using the power of the law

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together with advocacy and education, LatinoJustice seeks to protect opportunities for all Latinos

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to succeed in school and work, fulfill their dreams, and sustain their families and communities.

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LatinoJustice has litigated numerous landmark cases addressing issues enabling Latinos to secure

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equal opportunities in their communities and workplaces.
The Legal Aid Justice Center (“LAJC”) is a statewide non-profit legal aid organization in

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Virginia that provides legal advice, referrals, and direct representation to thousands of low-

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income immigrant children and adults each year who cannot afford private counsel. Through its

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legal and community organizing work with immigrant communities around Virginia, LAJC has

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learned that communities are safer when immigrants and state/local law enforcement work

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together from a position of trust, keeping federal immigration enforcement concerns out of local

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policing. This is why LAJC started the “De-ICE Virginia” campaign: to keep local law

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enforcement out of the business of breaking up immigrant families and dividing immigrant

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communities.

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The Legal Aid Society of San Mateo County provides legal services to San Mateo

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County’s low-income residents. Through the Linking Immigrants to Benefits, Resources &

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Education (“LIBRE”) program, the Legal Aid Society of San Mateo County collaborates with

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community partners to educate the immigrant community about safety net services and provide

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accurate information concerning their immigration opportunities.

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Legal Services for Children (“LSC”) provides free representation to children and youth

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who require legal assistance to stabilize their lives and realize their full potential. Through a

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holistic team approach utilizing legal advocacy and social work services, its goal is to empower

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clients and actively involve them in the critical decisions that impact their lives. LSC uses this
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model to achieve safety and stability at home; educational success; and freedom from detention

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and deportation for its clients. LSC believes that it is critical to the wellness of all California

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children that every family, regardless of status, feels safe accessing essential services including

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education services, health services, and law enforcement.

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The Long Beach Immigrant Rights Coalition is a grassroots network of community

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organizations and individuals working for just immigration policies and practices that respect

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human rights and the dignity of immigrants, through education, services, and advocacy. The

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Coalition envisions a state that serves as a model for a country where all, regardless of

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immigration status, are guaranteed a fulfilling and prosperous political, economic, and social life.

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The Los Angeles Center for Law and Justice (“LACLJ”) is a Los Angeles-based non-

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profit organization that has been providing culturally competent free legal services to low-

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income residents of Los Angeles and their families for over 40 years. LACLJ’s mission is to

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fight for the rights of vulnerable families and advocate for a more just legal system. LACLJ has

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represented hundreds of individuals who have applied for immigration relief based on having

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survived domestic violence, sexual assault, human trafficking, and/or other violent crimes.

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LACLJ can thus speak to heightened levels of fear in the immigrant community and how critical

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it is for immigrant survivors in particular, and the entire immigrant community in general, to

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continue to have access to protections that ensure their ability to safely report crime and access

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the courts, along with other vital services.

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The Lowcountry Immigration Coalition provides a forum for the establishment of a group

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of individuals, representing the Lowcountry of South Carolina and related communities, in

22

supporting efforts toward comprehensive immigration reform policies in the community,

23

statewide, and nationally. The Coalition seeks to educate, inform, communicate, and advocate in

24

support of immigration policies to advance a human rights agenda, including the protection of

25

civil liberties, prevention of discrimination, and education on cultural awareness. The Coalition

26

supports legal mechanisms locally and nationwide that limit the adverse effect of policies

27

deleterious to the Hispanic and Latino communities wherever they may occur.

28
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The Maintenance Cooperation Trust Fund (“MCTF”) is a California statewide watchdog

2

organization working to abolish illegal and unfair business practices in the janitorial industry.

3

The MCTF exposes unlawful operations, encourages accountability, promotes responsible

4

business practices, and helps level the playing field in the interest of clients, employers, workers,

5

and the general public. Many of the workers the MCTF has assisted are immigrant workers who

6

are unfamiliar with their rights and protections as workers in the state of California, and who

7

face retaliation from employers for reporting a wage and hour violation, an injury, or a health

8

hazard at work. Many times, the retaliation is in the form of a threat to report them or a family

9

member to Immigration Customs Enforcement or to re-verify their immigration status. The

10

MCTF is interested in supporting policies that promote the enforcement of the rights of

11

immigrant workers, as well as their well-being and sense of inclusion as community members.

12

Michigan Migrant Legal Assistance Project Inc. (“MMLAP”) is a civil legal aid program

13

devoted to protecting indigent migrant and seasonal farmworker rights through litigation and

14

advocacy. During the course of 44 years, MMLAP’s legal victories have established important

15

legal precedents in published cases and advanced the labor and civil rights of migrant workers in

16

Michigan. MMLAP’s work is greatly enhanced by state and local policies that promote equality

17

and inclusion of all community members, regardless of their national origin.

18

The Miguel Contreras Foundation (“MCF”) is the program partner of the Los Angeles

19

County Federation of Labor, AFL-CIO, with a mission to empower working Angelinos –

20

especially immigrants and communities of color – by advancing greater equity through access to

21

good quality jobs and livable communities. MCF's programs seek to ensure that Los Angeles

22

County supports underserved workers who are the backbone of our thriving economy and an

23

essential part of the rich fabric of our society. All workers, regardless of immigration status, are

24

entitled to the dignity of honest pay for an honest day’s work, safe working conditions, and their

25

basic rights to fair treatment and collective organizing in the workplace and beyond. MCF seeks

26

to uplift the millions of immigrant workers who co-powered California into the world’s fifth

27

largest economy.

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The National Employment Law Project (“NELP”) is a non-profit legal organization with

2

over 45 years of experience advocating for the employment and labor rights of low-wage

3

workers. NELP seeks to ensure that all workers, especially the most vulnerable ones, receive the

4

full protection of labor and employment laws, regardless of immigration status. NELP has

5

litigated and participated as amicus in numerous cases addressing the rights of workers.

6

The National Immigrant Justice Center (“NIJC”) is a program of Heartland Alliance,

7

headquartered in Chicago, Illinois. NIJC, through its staff of attorneys, paralegals, and a

8

network of over 1,500 pro bono attorneys, provides free or low-cost legal services to immigrants,

9

including detained non-citizens. NIJC’s direct representation, as well as its immigration advisals

10

to criminal defense attorneys, has informed its strategic policy and litigation work around the

11

myriad legal and policy problems of entangling local law enforcement in civil immigration

12

enforcement.

13

The New York Immigration Coalition (“NYIC”) represents over 200 organizational

14

members and partners working on behalf of immigrants throughout New York State. The NYIC

15

envisions a New York State that is stronger because all people are welcome, treated fairly, and

16

given the chance to pursue their dreams. NYIC achieves this by representing the collective

17

interests of New York’s diverse immigrant communities and organizations and devising

18

solutions to advance them; advocating for laws, policies, and programs that lead to justice and

19

opportunity for all immigrant groups; and building the power of immigrants and the

20

organizations that serve them to ensure their sustainability, to improve people’s lives and to

21

strengthen New York State.

22

The Northwest Health Foundation works to advance the health of the people of Oregon

23

and Southwest Washington. The Foundation recognizes, and the data show, that health and

24

wellbeing is determined by many factors including a sense of inclusion.

25

The Northwest Immigrant Rights Project (“NWIRP”) is a nationally-recognized legal

26

services organization based in Washington State. Each year, NWIRP provides direct legal

27

assistance in immigration matters to over 10,000 low-income people from over 140 countries,

28

speaking over 60 different languages and dialects. NWIRP also strives to achieve systemic
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change to policies and practices affecting immigrants through impact litigation, public policy

2

work, and community education. Founded in 1984, NWIRP serves the community from four

3

offices in Washington State. NWIRP has a deep interest in the subject of this litigation because

4

it advocates for policies at the state and local level that will promote the well-being of all

5

residents of our communities and is therefore concerned with federal preemption arguments that

6

may limit the ability of state and local jurisdiction to enact such policies.

7

OneAmerica is the largest immigrant and refugee organizing, civic engagement, and

8

advocacy organization in Washington State. OneAmerica was founded as a community response

9

to the backlash against Muslims, Sikhs, undocumented immigrants, and refugees following the

10

9/11 terrorist attacks. OneAmerica’s mission is to build the power of immigrant and refugee

11

communities with key allies to advance the fundamental principles of justice and democracy.

12

OneAmerica has successfully advocated for administrative and legislative policy changes at the

13

state and local level to prevent immigrant and refugee families from being separated by

14

immigration enforcement actions. Ensuring that state and local governments have the authority

15

to adopt and implement policies that promote the wellbeing and belonging of all communities is

16

an organizational priority consistent with OneAmerica’s mission and purpose.

17

OneJustice is a statewide legal services organization working to bring life-changing legal

18

help to those in need by transforming the civil justice system. Since 1979, OneJustice has

19

worked with civil justice nonprofits, law firms, corporations, and law schools to strengthen and

20

expand California's legal services delivery system serving immigrants, veterans, seniors, and

21

families. OneJustice coordinates the California Immigration Pro Bono Network, engaging the

22

private sector in ensuring pro bono immigration services in partnership with local legal services

23

and social services nonprofits and immigrant communities throughout the state.

24

The Oregon Interfaith Movement for Immigrant Justice, a member of Oregon Ready, is

25

an organization made up of diverse faith communities, faith leaders, and individuals called by

26

conscience to respond actively and publicly to the suffering of our immigrant brothers and sisters

27

in the U.S. Through advocacy, accompaniment, and organizing, the organization exposes the

28

injustices current immigration policies inflict on the entire community and take radical action for
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the transformation of power, providing real opportunities to take action for change. Just as we

2

open our hearts to provide welcome and accompaniment to people facing persecution and

3

oppression, the Oregon Interfaith Movement for Immigrant Justice opens our doors to offer

4

sanctuary for immigrants faced with family separation, detention, or deportation.

5

The Oregon Justice Resource Center (“OJRC”) is a Portland based, non-profit

6

organization founded in 2011. OJRC works to promote civil rights and improve legal

7

representation to traditionally underserved communities, including non-citizens. OJRC serves

8

this mission by focusing on the principle that our justice system should be founded on fairness,

9

accountability, and evidence-based practices. The OJRC’s Immigrant Rights Project provides

10

personalized advice to public defense providers regarding the immigration consequences of pleas

11

and convictions for non-citizens.

12

Pangea Legal Services (“Pangea”) is a non-profit organization based in San Francisco

13

and Santa Clara County, California, that provides low-cost and free legal services to immigrants

14

in removal proceedings. In addition to direct legal services, Pangea also advocates on behalf of

15

the immigrant community through policy advocacy, education, and legal empowerment efforts.

16

Pangea represents detained and non-detained immigrants who have an interest in exposing illegal

17

conditions in ICE detention facilities and preventing the enmeshment of local police with

18

immigration enforcement.

19

Presente Action is the nation’s largest online Latinx organizing group, with 500,000

20

registered member volunteers nationwide, and advances social justice with technology, media,

21

and culture. Since 2009, Presente Action has worked to protect the fundamental human rights,

22

safety, and livelihoods of millions of immigrants by helping to organize public support for

23

DREAMers (recipients of Deferred Action for Childhood Arrivals (“DACA”)) and Temporary

24

Protected Status (TPS) holders and by strengthening nationwide public responses to attacks on

25

our communities. Presente Action is deeply concerned that federal preemption of California

26

laws, like SB 54, will erode necessary and legal protections for immigrants and instill a culture

27

of fear, which has dramatic effects on health, safety, and well-being.

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1

Public Advocates Inc. is one of the oldest public interest law firms in the nation.

2

Founded in 1971 to challenge the persistent, underlying causes and effects of poverty and

3

discrimination and to work for the empowerment of the poor and people of color by raising a

4

voice for social justice in government, corporate, and other institutions, Public Advocates has

5

represented immigrants in protecting their rights under California law to public education as well

6

as prenatal care and emergency health care regardless of documentation status. Through

7

litigation and policy advocacy, Public Advocates has worked to expand educational opportunities

8

and achievement for English Learners and children of immigrants generally in California’s

9

public schools, and to provide immigrant families and residents with access to affordable

10
11

housing and public transportation opportunities.
Public Counsel, based in Los Angeles, California, represents indigent immigrants from

12

around the world in their claims for immigration relief. Public Counsel has provided legal

13

services to thousands of immigrants detained by the Department of Homeland Security,

14

including through legal orientations, pro se assistance, direct representation, and impact

15

litigation. Public Counsel is committed to advancing transparency, equality, and justice in our

16

nation’s immigration system.

17

The Public Justice Center is a civil rights and poverty law legal advocacy organization

18

with a longstanding commitment to immigrants’ rights. Through its race equity and immigrants’

19

rights projects, it seeks to achieve economic equity, work with dignity, safety, access to health

20

care, and other elements of the American quality of life for all.

21

The Refugee and Immigrant Center for Education and Legal Services (“RAICES”) is a

22

non-profit legal services and refugee resettlement agency with seven offices throughout Texas.

23

RAICES seeks justice for immigrants through a combination of legal and social services,

24

advocacy, policy, and litigation. In 2017, RAICES provided legal services to over 20,000

25

immigrants and refugees. As one of the largest immigration legal services providers in Texas,

26

the population that RAICES serves is directly impacted by federal, state, and local policies,

27

decisions, and activities that affect the safety, security, and sense of community of immigrants

28

and refugees, such as those that are the subject of this suit.
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The San Diego Chapter of the American Immigration Lawyers Association (“AILA San

2

Diego”) is the regional chapter of the national association of attorneys who practice and teach

3

immigration law in San Diego and Imperial Counties. The immigration lawyers who practice in

4

the border region know first-hand how imperative it is to have systems in place to counteract the

5

far-reaching nature of unjust immigration enforcement. AILA San Diego attorneys are proud to

6

stand with their clients and colleagues in defense of these essential state laws.

7

The San Diego Immigrant Rights Consortium is a coalition of over 50 organizations

8

across San Diego County. Since 2007, the San Diego Immigrant Rights Consortium has brought

9

together faith, labor, legal, and community groups to advance the rights of immigrants. The

10

Consortium stands in strong support of the California Values Act.

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The San Diego LGBT Community Center is one of the oldest and largest LGBT

12

community centers in the nation. Functioning as the LGBT community’s anchor organization

13

since 1972, The Center is led by a 12-member board of directors, employs over 50 paid staff, and

14

utilizes more than 1,200 community volunteers to achieve its mission to enhance and sustain the

15

health and well-being of the lesbian, gay, bisexual, transgender, and HIV communities by

16

providing activities, programs, and services that create community; empower community

17

members; provide essential resources; advocate for civil and human rights; and embrace,

18

promote, and support our cultural diversity.

19

Services, Immigrant Rights, and Education Network (“SIREN”) is a leading grassroots

20

organization serving the immigrant and refugee communities in Northern and Central California.

21

For over 30 years, SIREN has provided immigration legal services, engaged in community

22

organizing and civic engagement, and conducted policy advocacy on issues affecting these

23

communities. SIREN works directly with community members who have benefited from state

24

and local policies that limit entanglement between federal immigration agencies and local

25

governments and those who have been affected by immigration enforcement at worksites and

26

being held in detention.

27

The Sierra Club is a national nonprofit organization of approximately 825,000 members,

28

roughly 180,000 of whom live in California, dedicated to exploring, enjoying, and protecting the
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wild places of the earth; to practicing and promoting the responsible use of the earth’s

2

ecosystems and resources; to educating and encouraging humanity to protect and restore the

3

quality of the natural and human environment; and to using all lawful means to carry out these

4

objectives. To protect clean air and water and prevent the disruption of our climate, the Sierra

5

Club recognizes that we must ensure that those who are most disenfranchised and most

6

threatened by pollution within our borders have the voice to fight polluters and advocate for

7

climate solutions without fear. The Sierra Club has taken various actions to support and stand in

8

solidarity with immigrants – the struggles to protect our communities and our environment

9

cannot be separated. The Sierra Club has supported and participated in passage of SB 54, one of

10

the bills under attack, out of the strongly-held belief that the federal government's growing focus

11

on identifying and deporting long-time residents from other countries undercuts our

12

environmental work.

13

Sin Barreras-Without Borders, Inc. is a volunteer non-governmental organization in

14

Charlottesville, Virginia, dedicated to defending and advancing the rights and opportunities of

15

low-income immigrants and their families. Over the past six years, the organization has worked

16

to address Hispanic rights through workshops, one-on-one legal and immigration services, and

17

advocacy with like-minded organizations in Central Virginia. The organization supports state

18

and local policies that promote the wellbeing and sense of inclusion of all community members.

19

South Bay People Power is a grassroots organization that promotes social justice by

20

nonpartisan civic engagement. Over the past year and a half, the organization has successfully

21

advocated for enactment of a series of local policies to ensure the rights of immigrants. The

22

organization is concerned about the ability of the state and localities to take action to protect

23

community members living in the border region of San Diego County.

24

The Southern CA Coalition for Occupational Safety & Health (“SoCalCOSH”) is a

25

grassroots membership organization of workers, unions, community-based groups, workers’

26

rights activists, and health and safety professionals. Based in Los Angeles, it is part of a national

27

network of workers, worker centers, labor unions, university centers, legal aid groups, and allies

28

who discuss, apply analysis, and mobilize toward achieving a fair and just relationship between
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workers’ safety and health and their employers. As an advocate for workers, SoCalCOSH is

2

concerned that the atmosphere of fear around immigration enforcement, stoked by the federal

3

government’s attack on California’s immigration laws and immigrant communities, dissuades

4

workers from exercising their rights and reporting dangerous health and safety conditions,

5

workplace injuries, or wage theft.

6

St. John’s Well Child and Family Center is a network of nonprofit federally qualified

7

health centers providing medical, dental, and mental health services to more than 350,000 patient

8

visits each year in Los Angeles County. As the largest provider of healthcare services to

9

undocumented immigrants in the country, St. John’s believes that everyone has a fundamental

10
11

right to health.
Student Action with Farmworkers (“SAF”) is an organization whose mission is to bring

12

students and farmworkers together to learn about each other’s lives, share resources and skills,

13

improve conditions for farmworkers, and build diverse coalitions for social change. As an

14

organization that has been around for twenty-five years, SAF has witnessed and heard

15

farmworkers and their families testify about the experiences they have had in the fields and in

16

their communities. SAF wishes to support legislation that promotes a feeling of safety within

17

farmworker and immigrant communities as found in SB 54, AB 450, and AB 103.

18

T.R.U.S.T. South LA (Tenemos que Rescatar y Unidos Salvar la Tierra) is a non-profit

19

organization that works with low-income and immigrant community residents to transform the

20

built environment and social conditions in South Los Angeles by serving as a steward for

21

community-controlled land; being a catalyst for values-driven, community-serving development;

22

building awareness and community leadership in issues of housing, transportation, and

23

recreation; and creating programs and initiatives that encourage community building and

24

economic opportunity.

25

UnidosUS (formerly the National Council of La Raza) is the nation’s largest Latino civil

26

rights and advocacy organization. Through its unique combination of research, advocacy,

27

programs, and a national network of nearly 300 community-based Affiliate organizations across

28

the country (56 of them in California), UnidosUS simultaneously challenges the social,
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economic, and political barriers that affect Latinos in the United States. UnidosUS supports

2

policies that advance the public safety of all residents, protect all workers, and create

3

opportunities to integrate newcomers. UnidosUS has learned from experience that without

4

measures like the ones passed in California, trust between residents and law enforcement breaks

5

down, communities report fewer crimes, and law enforcement’s job to keep everyone safe is a lot

6

more difficult.

7

The United Farm Workers Foundation is the fastest-growing, non-profit immigration

8

legal services provider with the largest number of Office of Legal Access Programs Accredited

9

Representatives (“OLAP”) in California. The Foundation has been able to assist with more than

10

13,000 legal immigration direct services and educate more than 160,000 community members on

11

Naturalization, DACA, Know Your Rights, Heat Illness Prevention, and Public Benefit

12

eligibility throughout Coastal and Central California. The Foundation’s mission is to empower

13

communities to ensure human dignity, and it envisions a clear path to social integration and civic

14

participation for immigrants and their children.

15

The Washington Defender Association’s Immigration Project is part of the Washington

16

Defender Association (“WDA”). WDA is a statewide non-profit organization whose members

17

are public defender agencies, indigent defenders, and those working to improve the quality of

18

indigent defense in Washington State. WDA provides support for high quality legal

19

representation by advocating for change, educating defenders, and collaborating with the

20

community and justice system stakeholders to bring about just solutions. In 1999, WDA created

21

the Immigration Project to defend and advance the rights of noncitizens within the Washington

22

State criminal justice system and noncitizens facing the immigration consequences of crimes.

23

White People 4 Black Lives (“WP4BL”) is a white anti-racist collective and activist

24

project of the Alliance of White Anti-Racists Everywhere (“AWARE”). The organization also

25

operates within a national network of white anti-racists called Showing Up for Racial Justice

26

(“SURJ”). WP4BL is concerned with the impact of national and local policies and practices that

27

predominantly target low-income communities of color. These primarily involve harmful

28
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policing and detention practices that separate families and undermine community safety,

2

security, and wellbeing.

3

The Worker Justice Center of New York (“WJCNY”) has, since 1981, pursued justice for

4

those denied human rights with a focus on agricultural and other low-wage workers, through

5

legal representation, community empowerment, and advocacy for institutional change. WJCNY

6

strongly believes that the positions of the attached brief advance public safety, prevent the

7

mistreatment of undocumented individuals (and others who are believed to be undocumented),

8

protect workers and workplace standards, and protect the health and safety of immigrant

9

detainees.

10

Worksafe, Inc., is a California-based non-profit organization dedicated to promoting

11

occupational safety and health through education, training, and advocacy. Worksafe advocates

12

for protective worker health and safety laws and effective remedies for injured workers through

13

the legislature and courts. Worksafe is also a Legal Support Center funded by the State Bar

14

Legal Services Trust Fund Program to provide advocacy, technical and legal assistance, and

15

training to the legal services projects throughout California that directly serve California’s most

16

vulnerable low-wage workers. Worksafe has an interest in the outcome of this case as it

17

determines the validity of important legislation to workers.

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Amici have a significant stake in this case, and their brief brings to bear their collective
wisdom on the issues before the Court.
For the reasons stated above, amici respectfully request that the Court grant their motion

21

to file a brief as amici curiae.

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Dated: May 18, 2018

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Respectfully submitted,
/s/ Jonathan Weissglass
Jonathan Weissglass
Law Office of Jonathan Weissglass
410 12th Street, Suite 250-B
Oakland, CA 94607
Telephone: [phone]
E-mail: [e-mail]

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Nicholas Espíritu
Jana Whalley
National Immigration Law Center
3450 Wilshire Boulevard, #108-62
Los Angeles, CA 90010
Telephone: [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Amici Curiae

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