State of Washington, et al., v. Trump., et al

Filing 144

MOTION for Leave to file Brief of Amici Curiae and Brief of Amici Curiae, filed by Amicus City of Chicago. (Attachments: # 1 Exhibit Appendix) Noting Date 3/14/2017, (Solomon, Benna)

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___________________________________________________ APPENDIX ___________________________________________________ Additional Counsel for Amici Curiae ZACHARY W. CARTER Corporation Counsel of the City of New York 100 Church Street New York, New York 10007 Attorney for Mayor and the City Council of New York MICHAEL N. FEUER City Attorney of the City of Los Angeles 200 N. Main Street, 800 CHE Los Angeles, CA 90012 (213) 978-8100 mike.feuer@lacity.org Attorney for City of Los Angeles EUGENE L. O’FLAHERTY Corporation Counsel One City Hall Square, Room 615 Boston, MA 02201 (617) 635-4034 eugene.oflaherty@boston.gov Attorney for Boston and Mayor Martin J. Walsh GREGORY L. THOMAS City Attorney for the City of Gary, Indiana 401 Broadway, Suite 101 Gary, IN 46402 (219) 881-1400 glthomas@ci.gary.in.us Attorney for Gary MATTHEW T. JERZYK City Solicitor 580 Broad Street Central Falls, RI 02863 (401) 616-2435 MJerzyk@CentralFallsRI.us Attorney for James A. Diossa, Mayor of Central Falls, Rhode Island AARON O. LAVINE City Attorney 108 E. Green St. Ithaca, NY 14850 (607) 274-6504 Attorney for Svante L. Myrick, Mayor of Ithaca JEREMY FARRELL Corporation Counsel Jersey City Law Department 280 Grove Street Jersey City, New Jersey 07302 Attorney for City of Jersey City KIMBERLY M. FOXX States Attorney for Cook County 69 W. Washington, 32nd Floor Chicago, IL 60602 (312) 603-6934 kent.ray@cookcountyil.gov Attorney for Cook County, Illinois MICHAEL P. MAY City Attorney 210 Martin Luther King Jr. Blvd., Room 401 Madison, Wisconsin 53703 (608) 266-4511 Attorney for City of Madison A1 SUSAN L. SEGAL City Attorney 350 South 5th Street, Room 210 Minneapolis, MN 55415 (612) 673-3272 Susan.segal@minneapolismn.gov Attorney for City of Minneapolis SAMUEL J. CLARK City Attorney 400 City Hall 15 Kellogg Blvd W Saint Paul, MN 55102 (651) 266-8710 samuel.clark@ci.stpaul.mn.us Attorney for City of Saint Paul MARC P. HANSEN County Attorney Montgomery County, Maryland 101 Monroe St., 3rd Floor Rockville, Maryland, 20850 (240) 777-6740 Marc.Hansen@montgomerycountymd. gov Attorney for Montgomery County MARA W. ELLIOTT City Attorney City of San Diego 1200 Third Ave., Suite 1600 San Diego, CA 92101 Attorney for City of San Diego BARBARA J. PARKER City Attorney 1 Frank H. Ogawa Plaza, Sixth Floor Oakland, California 94612 (510) 238-3814 Bparker@oaklandcityattorney.org Attorney for Oakland DENNIS J. HERRERA San Francisco City Attorney City Attorney’s Office City Hall Room 234 One Dr. Carlton B. Goodlett Pl. San Francisco, California 94102 (415) 544-4700 Attorney for City and County of San Francisco TRACY REEVE City Attorney 430 City Hall 1221 SW Fourth Ave. Portland, OR 97204 (503) 823-4047 Tracy.Reeve@portlandoregon.gov Attorney for Portland RICHARD DOYLE City Attorney City of San José 200 East Santa Clara St., 16th Floor San José, CA 95113 (408) 535-1900 richard.doyle@sanjoseca.gov Attorney for City of San Jose SOZI PEDRO TULANTE City Solicitor City of Philadelphia Law Department 1515 Arch Street, 17th Floor Philadelphia, PA 19102 Attorney for City of Philadelphia JAMES R. WILLIAMS County Counsel OFFICE OF THE COUNTY COUNSEL 70 West Hedding Street, 9th Floor San Jose, California 95110-1770 (408) 299-5900 Attorney for Santa Clara County A2 JOSEPH LAWRENCE Interim City Attorney City of Santa Monica 1685 Main Street, Room 310 Santa Monica, CA 90401 (310) 458-8336 Attorney for City of Santa Monica PETER S. HOLMES Seattle City Attorney 701 Fifth Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 peter.holmes@seattle.gov Attorney for City of Seattle MICHAEL M. LORGE Corporation Counsel 5127 Oakton Avenue Skokie, IL 60077 (847) 933-8270 Attorney for Village of Skokie CRISTAL BRISCO Corporation Counsel City of South Bend Department of Law 227 W. Jefferson Blvd., Suite 1200S South Bend, IN 46601 (574) 235-9241 cbrisco@southbendin.gov Attorney for South Bend MICHAEL JENKINS JENKINS & HOGIN, LLP 1230 Rosecrans Avenue, Suite 110 Manhattan Beach, CA 90266 (310) 643-8448 MJenkins@LocalGovLaw.com Attorney for West Hollywood A3 IMPACT OF THE EXECUTIVE ORDER ON THE CITY OF CHICAGO The population of our metropolitan area is 2,717,534.1 We have residents from more than 127 foreign countries.2 At least 572,066 of our residents are immigrants.3 3,731 of Chicago residents were born in Iran, Libya, Somalia, Sudan, Syria, and Yemen, of which 1,650 residents are non-citizen immigrants from these countries.4 Approximately 1.27 million people are employed in Chicago.5 Of those, 26.5% are foreign-born immigrants,6 including an estimated 976 non-citizen immigrants from the six targeted countries.7 The City of Chicago itself employs more than 32,000 people.8 Approximately 27% of Chicago’s business owners are immigrants,9 of whom an estimated 0.7% come from the six targeted countries.10 In 2016, approximately 2,091 refugees were resettled in our city, including 794 from the six targeted countries.11 City Colleges of 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.12 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.13 1 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. Id. 3 Id. 4 U.S. Census Bureau, American Community Survey PUMS 1-Year 2015 Data. 5 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 6 Id. 7 Id. 8 https://www.cityofchicago.org/city/en/depts/dhr/dataset/current_employeenames salariesandpositiontitles.html 9 https://www.americanimmigrationcouncil.org/research/new-americans-illinois 10 Id. 11 U.S. Department of State, Bureau of Population, Refugees and Migration, Office of Admissions – Refugee Processing Center. Available at http://ireports.wrapsnet.org/ 12 Jeff Donoghue, CCC. Accessed 3/9/17; includes Credit students only. 2 A4 On any given day, 232 flights arrive at Chicago airports from international destinations, bringing 31,856 passengers.14 Each international flight arrival yields approximately $212,000 in local economic impact.15 In 2016, Chicago welcomed 54.1 million visitors,16 1.62 million of whom visited from overseas.17 Approximately 1000 international visitors were from the six targeted countries.18 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.19 The average overseas visitor spends about $2,313 per trip while visiting Chicago.20 Tourists from the six countries account for an estimated $1.25 million of local economic impact per year.21 The City of Chicago established the Chicago Legal Protection Fund (“the Fund”) to increase legal services for immigrant communities across the city.22 $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.23 13 Alfred Orendorff (ChooseChicago). http://www.flychicago.com/SiteCollectionDocuments/OHare/AboutUs/Facts and Figures/Air Traffic Data/1216 ORD SUMMARY.pdf 15 Jonathan Leach, Chicago Department of Aviation. 16 https://www.cityofchicago.org/city/en/depts/mayor/press_room/press_releases /2016/april/Mayor-Choose-Chicago-Announce-Record-Tourism-2015.html 17 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 18 Alfred Orendorff (ChooseChicago). 19 Id. 20 Id. 21 Id. 22 Seemi Choudry, Director of Office of New Americans, City of Chicago. 23 Id. 14 A5 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.24 In calendar year 2016, NIJC and TRP represented clients from at least 132 countries, including clients from each of the six targeted countries.25 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.26 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 2016.27 24 Id. Id. 26 Brandon Nemec, Mayor’s Office liaison with Chicago Police Department. 27 Zak Koeske, Hate crimes in Chicago rose 20 percent in 2016, marking 5-year high, police data show, Chicago Tribune (Mar. 3, 2017). 25 A6 IMPACT OF THE EXECUTIVE ORDER ON NEW YORK CITY The population of our metropolitan area is 8,550,405 as of 2015.28 We have residents from more than 150 foreign countries.29 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.30 New York City is home to an estimated 27,000 individuals born in Sudan, Yemen, Syria, Iran, Iraq, Somalia, and Libya. Overall, NYC is home to over 46,000 residents of Sudanese, Yemeni, Syrian, Iranian, Iraqi, Somali, or Libyan ancestry.31 Approximately 4.3 million people are employed in New York City; of those, 46% are foreign-born immigrants, including approximately 5,600 non-citizen immigrants from the seven targeted countries.32 New York City itself employs 287,000 people.33 51% of New York City’s business owners are immigrants.34 About 1,300 refugees have been resettled in New York City in the last 5 years, according to federal data.35 The tourism sector of New York City’s local economy includes direct visitor spending in 2015 of $42.2 billion.36 In 2015, New York City welcomed 58.5 million visitors, including 12.3 million foreign visitors.37 28 http://www.census.gov/quickfacts/table/PST045215/3651000 Our Immigrant Population Helps Power NYC Economy, Comptroller Scott Stringer, 2017 30 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. 31 Id. 32 Id. 33 https://www.nytimes.com/2016/10/12/nyregion/bill-de-blasio-governmentjobs.html?_r=0. 34 Our Immigrant Population Helps Power NYC Economy, Comptroller Scott Stringer, 2017 35 Data compiled by the Bureau of Population, Refugees, and Migrants Office of Admissions—Refugee Processing Center. 36 http://www.nycandcompany.org/research/nyc-statistics-page 37 Id. 29 A7 New York City has 87 four-year colleges and universities, and these have approximately 50,000 international students.38 In the three months following the 2016 Presidential election, New York City has characterized 43 crimes as possible hate crime incidents.39 This is an increase of 115% for the same three-month period.40 38 46,870 foreign students were enrolled during the 2012–2013 school year. https://www.nycedc.com/blog-entry/international-students-nyc. 39 NYPD Reports ‘Huge Spike’ in Hate Crimes Since Donald Trump’s Election, NY Observer. 40 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. A8 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.41 We have residents from more than 135 foreign countries, and 185 languages are spoken here.42 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. 43 As of 2015, Los Angeles 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.44 Our city employs approximately 45,000 people, of which 22% are foreign-born immigrants. 44% of business owners in Los Angeles are immigrants.45 Between October 2016 and September 2017, 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.46 On any given day, 185 flights arrive at LAX from international destinations bringing 31,000 passengers, including more than 150 from the targeted countries.47 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.48 41 U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates. Id. 43 Id. 44 https://www.brookings.edu/blog/the-avenue/2017/01/30/these-communities-havea-lot-at-stake-in-trumps-executive-order-on-immigration/) 45 2010 ACS Single year estimate. 46 U.S. Department of State, Bureau of Population, Refugees and Migration, Office of Admissions – Refugee Processing Center 47 LAX officials. 48 Discover LA. 42 A9 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.49 Los Angeles has at least ten four-year colleges and universities, and these have approximately 25,000 international students.50 The Mayor of Los Angeles has reported that hate crime incidents doubled following the presidential election, with 30 such reported incidents during that month.51 49 Id. University enrollment data. 51 http://abc7.com/politics/garcetti-discusses-las-rise-in-hate-crimes-afterelection/1651429/ 50 A10

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