Filed Date: Feb. 6, 2018
Closed Date: March 29, 2019
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This action, filed on February 6, 2018, challenged the Department of Justice's "sanctuary city" policy tying federal funding to immigration enforcement. The plaintiff, the city of West Palm Beach, Florida ("the City"), sued the DOJ after the DOJ threatened to subpoena the City for records out of suspicion that the City might be noncompliant with immigration law and therefore ineligible for federal funding. The City argued it was fully compliant with federal law, and that linking funding to particular immigration laws violated the separation of powers, the Spending Clause, the Tenth Amendment, and the Administrative Procedure Act. The City filed this case in the U.S. District Court for the Southern District of Florida. It sought declaratory and injunctive relief.
The City argued that with nearly 27% of its population consisting of foreign-born individuals, immigrants were "an integral part of the City’s" civic, academic, and labor communities, and that the City depended on its immigrant population. In March 2017, the complaint explained, the City adopted a resolution seeking to keep information related to one's immigration and citizenship status private while expressly providing that federal laws superseded the resolution. The City's goal was "to foster trust between the immigrant population and City officials and employees, and to encourage people of all backgrounds to take full advantage of the City’s resources and opportunities."
Separately, the complaint explained that it had received nearly $400,000 in federal Byrne JAG funding since 2006. The City argued that starting November 2017, the DOJ began targeting it for alleged compliance issues with 8 U.S.C. § 1373, which prohibits localities from interfering with certain federal immigration enforcement measures. On January 25, 2017, President Trump issued an executive order tying federal funds to compliance with § 1373. The complaint stated that in a letter sent to the City in November 2017, the DOJ requested information addressing the status of the City's compliance with § 1373 and eligibility for Byrne JAG funding. The City responded to the letter to affirm its compliance and eligibility. In January 2018, the DOJ sent another letter indicating the City may be out of compliance and requesting that the City send documents relevant to the inquiry and that failure to do so would result in a subpoena.
Ultimately, the City argued that the DOJ had no statutory authority for imposing such conditions on the Byrne JAG grant. Even if Congress did intend to so authorize the DOJ, requiring certification of compliance with § 1373 violated the Spending Clause. Moreover, the City argued that its Resolution and laws were fully compliant with federal law, and that it was not a "sanctuary city."
On February 21, the City moved for preliminary injunction, seeking a declaration that it was compliant with § 1373. Shortly thereafter, the parties entered into mediation. On March 23, the parties indicated they had reached a settlement. The DOJ declared that the City was in compliance with federal law, and that it was therefore eligible for the federal grant. The City agreed to end the litigation and subsequently issued a memorandum to city employees clarifying that its laws did not preclude sharing information with federal immigration officials. The parties filed a joint stipulation of dismissal on March 28, and the court ordered the case closed the next day.
The case is now closed. The settlement agreement is not currently publicly available, though this page will be updated if becomes available.
Summary Authors
Virginia Weeks (3/30/2018)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6298257/parties/the-city-of-west-palm-beach-v-united-states-attorney-general/
Brannon, Dave Lee (Florida)
Brown, Alison K. (Florida)
Fresco, Leon (District of Columbia)
Attorney, Noticing INS (Florida)
Erickson−Pogorzelski, Anthony (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/6298257/the-city-of-west-palm-beach-v-united-states-attorney-general/
Last updated April 22, 2025, 8:22 a.m.
State / Territory: Florida
Case Type(s):
Special Collection(s):
Trump 1.0 & 2.0 Immigration Enforcement Order Challenges
Trump Administration 1.0: Challenges to the Government
Key Dates
Filing Date: Feb. 6, 2018
Closing Date: March 29, 2019
Case Ongoing: No
Plaintiffs
Plaintiff Description:
City of West Palm Beach, Florida
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
U.S. Department of Justice, Federal
Case Details
Causes of Action:
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Federalism (including 10th Amendment)
Available Documents:
Outcome
Prevailing Party: Mixed
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Content of Injunction:
Preliminary relief request withdrawn/mooted
Issues
General/Misc.:
Immigration/Border: