State of Hawaii v. Trump

Filing 247

MOTION for Leave to File Brief of Chicago, Los Angeles, New York, Philadephia, and Other Major Cities and Counties as Amici Curiae in Support of Plaintiffs' Motion to Convert the Temporary Restraining Order to a Preliminary Injunction (Dkt 238) Robert M. Kohn appearing for Amicus City and County of Honolulu (Attachments: # 1 Supplement Proposed Amici Curiae Brief, # 2 Appendix, # 3 Certificate of Service)(Kohn, Robert)

APPENDIX

IMPACT OF THE EXECUTIVE ORDER ON THE CITY OF CHICAGO
The population of the City of Chicago is 2,717,534.28
Chicago has residents from more than 127 foreign countries.29
At least 572,066 of our residents are immigrants.30
3,731 of Chicago’s residents were born in Iran, Libya, Somalia, Sudan, Syria, and
Yemen, of which 1,650 residents are non-citizen immigrants from these countries.31
Approximately 1.27 million people are employed in Chicago.32 Of those, 26.5% are
foreign-born immigrants,33 including an estimated 976 non-citizen immigrants from
the six targeted countries.34 The City of Chicago itself employs more than 32,000
people.35

Approximately 27% of Chicago’s business owners are immigrants,36 of whom an
estimated 0.7% come from the six targeted countries.37

At least 12,500 private employees in Chicago are working on international visas.38
In 2016, approximately 2,091 refugees were resettled in our city, including 794 from
the six targeted countries.39

Chicago has 34 four-year colleges and universities, and these have more than
13,789 international students in the 2015-16 academic year.40 City Colleges of

U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
Id.
30 Id.
31 U.S. Census Bureau, American Community Survey PUMS 1-Year 2015 Data.
32 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
33 Id.
34 Id.
35 https://www.cityofchicago.org/city/en/depts/dhr/dataset/current_employeenames
salariesandpositiontitles.html
36 https://www.americanimmigrationcouncil.org/research/new-americans-illinois
37 Id.
28
29

38

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 at
http://ireports.wrapsnet.org/
39

A1

Chicago (CCC) has 7 colleges, and these had approximately 558 international
students in the 2015-16 academic year. Of these, 175 CCC students were born in,
arrived on visas from, or are nationals of the six countries.41

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.42

On any given day, 232 flights arrive at Chicago airports from international
destinations, bringing 31,856 passengers.43

Each international flight arrival yields approximately $212,000 in local economic
impact.44

In 2016, Chicago welcomed 54.1 million visitors,45 1.62 million of whom visited from
overseas.46 Approximately 1000 international visitors were from the six targeted
countries.47

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.48

The average overseas visitor spends about $2,313 per trip while visiting Chicago.49

Tourists from the six countries account for an estimated $1.25 million of local
economic impact per year.50

http://www.collegesimply.com/colleges/illinois/chicago/four-year-colleges/;
http://www.iie.org/Research-and-Publications/Open-Doors/Data/Fact-Sheets-by-USState/2016 - .WJe7MrYrJTY
41 Jeff Donoghue, CCC. Accessed 3/9/17; includes Credit students only.
42 Alfred Orendorff (ChooseChicago).
43 http://www.flychicago.com/SiteCollectionDocuments/OHare/AboutUs/Facts and
Figures/Air Traffic Data/1216 ORD SUMMARY.pdf
44 Jonathan Leach, Chicago Department of Aviation.
45 https://www.cityofchicago.org/city/en/depts/mayor/press_room/press_releases
/2016/april/Mayor-Choose-Chicago-Announce-Record-Tourism-2015.html
46 U.S. Department of Commerce, National Travel and Tourism Office. Original
source:
http://tinet.ita.doc.gov/outreachpages/download_data_table/2015_States_and_Cities.
pdf
47 Alfred Orendorff (ChooseChicago).
48 Id.
49 Id.
40

A2

The City of Chicago established the Chicago Legal Protection Fund (“the Fund”) to
increase legal services for immigrant communities across the city.51 $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.52
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.53

In calendar year 2016, NIJC and TRP represented clients from at least 132
countries, including clients from each of the six targeted countries.54

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.55

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 2016.56

Id.
Seemi Choudry, Director of Office of New Americans, City of Chicago.
52 Id.
53 Id.
54 Id.
55 Brandon Nemec, Mayor’s Office liaison with Chicago Police Department.
56 Zak Koeske, Hate crimes in Chicago rose 20 percent in 2016, marking 5-year
high, police data show, Chicago Tribune (Mar. 3, 2017).
50
51

A3

IMPACT OF THE EXECUTIVE ORDER ON NEW YORK CITY
The population of New York City is 8,550,405 as of 2015.57
We have residents from more than 150 foreign countries.58
New York City is home to 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.59

New York City is home to an estimated 26,566 individuals born in Sudan, Yemen,
Syria, Iran, Somalia, and Libya.60

Approximately 4.3 million people are employed in New York City; of those, 46% are
foreign-born immigrants.61 New York City itself employs 287,000 people,62 34% of
them foreign-born.63

51% of New York City’s business owners are immigrants.64
About 1,300 refugees have been resettled in New York City in the last 5 years,
according to federal data.65

The tourism sector of New York City’s local economy includes direct visitor
spending in 2015 of $42.2 billion.66

In 2015, New York City welcomed 58.5 million visitors, including 12.3 million
foreign visitors.67
http://www.census.gov/quickfacts/table/PST045215/3651000
Our Immigrant Population Helps Power NYC Economy, Comptroller Scott
Stringer, 2017
59 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
60 Id.
61 Id.
62 https://www.nytimes.com/2016/10/12/nyregion/bill-de-blasio-governmentjobs.html?_r=0.
63 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
64 Our Immigrant Population Helps Power NYC Economy, Comptroller Scott
Stringer, 2017
65 Data compiled by the Bureau of Population, Refugees, and Migrants Office of
Admissions—Refugee Processing Center.
66 http://www.nycandcompany.org/research/nyc-statistics-page
67 Id.
57
58

A4

New York City has 87 four-year colleges and universities, and these have
approximately 50,000 international students.68

In the three months following the 2016 Presidential election, New York City has
characterized 43 crimes as possible hate crime incidents.69 This is an increase
of 115% for the same three-month period.70

46,870 foreign students were enrolled during the 2012–2013 school
year. https://www.nycedc.com/blog-entry/international-students-nyc.
69 NYPD Reports ‘Huge Spike’ in Hate Crimes Since Donald Trump’s Election, NY
Observer.
70 http://www.ny1.com/nyc/all-boroughs/news/2016/12/5/since-election-day--nypdreports-a-spike-in-hate-crimes-around-the-city-compared-to-last-year.html.
68

A5

IMPACT OF THE EXECUTIVE ORDER ON THE CITY OF 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.71

We have residents from more than 135 foreign countries, and 185 languages are
spoken here.72

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. 73

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, 600 from
Sudan, 500 from Somalia, 100 from Yemen.74

Our city employs approximately 45,000 people, of which 22% are foreign-born
immigrants.

44% of business owners in Los Angeles are immigrants.75
Between October 2015 and September 2016, approximately 2,800 refugees were
resettled in Los Angeles County, including approximately 2,000 from the six
targeted countries, and 1,900 from Iran alone.76

On any given day, 185 flights arrive at LAX from international destinations
bringing 31,000 passengers, including more than 150 from the targeted countries. 77

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.

U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
Id.
73 Id.
74 https://www.brookings.edu/blog/the-avenue/2017/01/30/these-communities-havea-lot-at-stake-in-trumps-executive-order-on-immigration/)
75 2010 ACS Single year estimate.
76 U.S. Department of State, Bureau of Population, Refugees and Migration, Office
of Admissions – Refugee Processing Center
77 LAX officials.
71
72

A6

Tourism supports approximately 500,000 jobs in the leisure and hospitality
sectors.78

In 2016, Los Angeles welcomed 47 million visitors, of which 7.1 million 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.79

Los Angeles has at least ten four-year colleges and universities, and these have
approximately 25,000 international students.80
The Mayor of Los Angeles has reported that hate crime incidents doubled following
the presidential election, with 30 such reported incidents during that month.81

Discover LA.
Id.
80 University enrollment data.
81 http://abc7.com/politics/garcetti-discusses-las-rise-in-hate-crimes-afterelection/1651429/
78
79

A7

IMPACT OF THE EXECUTIVE ORDER ON THE CITY OF PHILADELPHIA
The population of the City of Philadelphia is approximately 1,526,006,82 and for the
Philadelphia Metropolitan Statistical Area, the estimated population is 6,051,170.83
Philadelphia has residents from more than 130 foreign countries.84
At least 197,563 of our residents are immigrants.85
Approximately 1,456 of Philadelphia residents were born in Iran, Libya, Somalia,
Sudan, Syria, and Yemen.86

Approximately 640,661 people are employed in Philadelphia, of which 108,010 are
foreign-born, a figure that does not include individuals who work in Philadelphia
but reside outside the city.87

In 2013, immigrants made up 14% of business owners in Philadelphia. 28% of the
area’s “Main Street” business owners, including 23% of retail store owners and 34%
of restaurant owners.88

In 2016, approximately 682 refugees were resettled in Philadelphia, including 176
from the six targeted countries.89
The Philadelphia Metropolitan Area is home to 31 four-year colleges and
universities, whose students include 21,273 international students.90

U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates.
U.S. Census Bureau, Annual Estimates of the Resident Population: April 1, 2010
to July 1, 2014 – United States – Metropolitan and Micropolitan
84 U.S. Census Bureau, Place of Birth for the Foreign-Born Population in the
United States, 2011-2015 American Community Survey 5-year estimates.
85 Id.
86 Id.
87 U.S. Census Bureau, Selected Characteristics of the Native and Foreign-Born
Populations, 2011 American Community Survey 5-Year Estimates.
88 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.as-coa.org/sites/default/files/
ImmigrantBusinessReport.pdf).
89 U.S. Department of State, Bureau of Population, Refugees and Migration, Office
of Admissions – Refugee Processing Center. Available at
http://ireports.wrapsnet.org/
90 CampusPhilly; Christine Farrugia, Rajika Bhandari, Ph.D., 2015 Open Doors,
Report on International Educational Exchange.
82
83

A8

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.91

In the 3 months since the Nov. 2016 election (11/16-01/17), 11 hate crimes were
reported to Philadelphia police. In the 3 month period around the same time last
year (11/15-01/16), 7 hate crimes were reported, a 157% increase.92 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.93

Philadelphia Convention and Visitors Bureau (Staff Person), citing Tourism as
an Economic Engine for Greater Philadelphia 2015 Visitation and Economic Impact
Report, available at http://files.visitphilly.com/Visit-Philly-2015-Visitation-andImpact-Full-Report.pdf.
92 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/Summary/MonthlySumHateUI.a
sp?rbSet=4
93 Philadelphia Commission on Human Relations.
91

A9