Case: United States v. State of Illinois

President Donald Trump

COMPLAINT filed by UNITED STATES OF AMERICA; (Neylan, Elisabeth) (Entered: 02/06/2025)

case assigned

CIVIL Cover Sheet (Neylan, Elisabeth) (Entered: 02/06/2025)

clerk's notice

ATTORNEY Appearance for Plaintiff UNITED STATES OF AMERICA by Elisabeth Jo Neylan (Neylan, Elisabeth) (Entered: 02/06/2025)

summons issued

CASE ASSIGNED to the Honorable Lindsay C. Jenkins. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 3). (dec, )

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (dec, )

SUMMONS Issued as to Defendants City Of Chicago, Cook County, THOMAS DART, Brandon Johnson, Toni Preckwinkle, in her official capacity as County Board of Commissioners President, J. B. Pritzker, Larry Snelling, State of Illinois, cook county board of commissioners (khg, )

MINUTE entry before the Honorable Lindsay C. Jenkins: In person initial status hearing set for April 15, 2025 at 9:00 a.m. in Courtroom 2119. Initial Status Report shall be filed by April 8, 2025. The report should comply with the requirements set forth in the Initial Status Report standing order, which can be found at Judge Jenkins's web page @ (http://www.ilnd.uscourts.gov, "District Judges", to "Judge Lindsay Jenkins", to "Initial Status Hearings" under Case Management Procedures"). The parties must follow all the standing orders for Judge Jenkins and all Local Rules, which can be found at the same web page. At the Initial Status hearing, the parties are to report on the following: (1) Possibility of settlement in the case; (2) if no possibility of settlement exists, the nature and length of discovery necessary (with specific dates) to get the case ready for trial; and (3) whether the parties jointly consent to proceed before the Magistrate Judge. At the Initial Status Hearing, the Parties shall be prepared to inform the Court about the extent of monetary damages in order for the Court to address the proportionality of discovery as required by Fed. R. Civ. P. 26. Mailed notice. (jlj, ) (Entered: 02/06/2025)

ATTORNEY Appearance for Defendants J. B. Pritzker, State of Illinois by Christopher Graham Wells (Wells, Christopher) (Entered: 02/13/2025)

ATTORNEY Appearance for Defendants J. B. Pritzker, State of Illinois by Alex Hemmer (Hemmer, Alex) (Entered: 02/13/2025)

ATTORNEY Appearance for Defendants J. B. Pritzker, State of Illinois by Alexandra Lane Reed (Reed, Alexandra) (Entered: 02/13/2025)

ATTORNEY Appearance for Defendants J. B. Pritzker, State of Illinois by Darren Bernens Kinkead (Kinkead, Darren) (Entered: 02/13/2025)

ATTORNEY Appearance for Defendants City Of Chicago, Brandon Johnson, Larry Snelling by Andrew W Worseck (Worseck, Andrew) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendant Cook County by Jessica Megan Scheller (Scheller, Jessica) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendant Cook County by Prathima Yeddanapudi (Yeddanapudi, Prathima) (Entered: 02/14/2025)

SUMMONS Returned Executed by United States of America as to All Defendants. (Attachments: # 1 Affidavit, # 2 Affidavit, # 3 Affidavit, # 4 Affidavit, # 5 Affidavit, # 6 Affidavit, # 7 Affidavit, # 8 Affidavit, # 9 Affidavit, # 10 Affidavit, # 11 Affidavit)(Neylan, Elisabeth) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendant Cook County by Jonathon D. Byrer (Byrer, Jonathon) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendants City Of Chicago, Brandon Johnson, Larry Snelling by Emily A Vernon (Vernon, Emily) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendants City Of Chicago, Brandon Johnson, Larry Snelling by Amie Leann Medley (Medley, Amie) (Entered: 02/14/2025)

ATTORNEY Appearance for Defendants City Of Chicago, Brandon Johnson, Larry Snelling by Ellen Wight Mclaughlin (Mclaughlin, Ellen) (Entered: 02/18/2025)

ATTORNEY Appearance for Defendant Cook County by Megan Marie Honingford (Honingford, Megan) (Entered: 02/18/2025)

MOTION by Defendants J. B. Pritzker, State of Illinois for leave to file excess pages (Unopposed) (Kinkead, Darren) (Entered: 02/24/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion by the State of Illinois for excess pages 18 is granted. Any motion the State intends to file should, if possible, include an agreed proposed briefing schedule consistent with the Court's standing order. Mailed notice. (jlj, ) (Entered: 02/25/2025)

MOTION by Defendants J. B. Pritzker, State of Illinois to set a briefing schedule for Defendants' Forthcoming Motions to Dismiss and for Leave to File Oversize Briefs (Jointly Filed) (Wells, Christopher) (Entered: 02/28/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for an extension and for excess pages 20 is granted. The Court imposes the following agreed briefing schedule on the motions to dismiss: The State, City, and County Defendants each have until March 4, 2025 to file any Rule 12(b) motion. The government's response is due by April 1, 2025; any replies are due by April 29, 2025. Opening motions by any Defendant may not exceed 25 pages. The government should request an appropriate page extension after the dismissal motions are filed. Emailed notice (cn). (Entered: 02/28/2025)

ATTORNEY Appearance for Defendants County Board of Commissioners, Thomas Dart, Toni Preckwinkle by Prathima Yeddanapudi (Yeddanapudi, Prathima) (Entered: 02/28/2025)

ATTORNEY Appearance for Defendants County Board of Commissioners, Thomas Dart, Toni Preckwinkle by Jessica Megan Scheller (Scheller, Jessica) (Entered: 02/28/2025)

MOTION by Defendants State of Illinois, J. B. Pritzker to dismiss Rule 12(B) (Wells, Christopher) (Entered: 03/04/2025)

MEMORANDUM by J. B. Pritzker, State of Illinois in support of motion to dismiss 24 (Wells, Christopher) (Entered: 03/04/2025)

ATTORNEY Appearance for Defendant Cook County by Edward M. Brener (Brener, Edward) (Entered: 03/04/2025)

MOTION by Defendant Cook County to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1), MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Cook County Pursuant to Rule 12(b)(6) (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MEMORANDUM by Cook County in support of motion to dismiss/lack of jurisdiction, Motion to Dismiss for Failure to State a Claim 27 (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MOTION by Defendants County Board of Commissioners, Toni Preckwinkle to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1), MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants County Board of Commissioners, Toni Preckwinkle Pursuant to Rule 12(b)(6) (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MEMORANDUM by County Board of Commissioners, Toni Preckwinkle in support of motion to dismiss/lack of jurisdiction,, Motion to Dismiss for Failure to State a Claim, 29 (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MOTION by Defendant Thomas Dart to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1), MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Thomas Dart Pursuant to Rule 12(b)(6) (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MEMORANDUM by Thomas Dart in support of motion to dismiss/lack of jurisdiction, Motion to Dismiss for Failure to State a Claim 31 (Yeddanapudi, Prathima) (Entered: 03/04/2025)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants City Of Chicago, Brandon Johnson, Larry Snelling (Worseck, Andrew) (Entered: 03/04/2025)

NOTICE by City Of Chicago, Brandon Johnson, Larry Snelling re MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants City Of Chicago, Brandon Johnson, Larry Snelling 33 Notice of Unconstitutionality (Worseck, Andrew) (Entered: 03/04/2025)

MEMORANDUM by City Of Chicago, Brandon Johnson, Larry Snelling in support of Motion to Dismiss for Failure to State a Claim 33 (Worseck, Andrew) (Entered: 03/04/2025)

ATTORNEY Appearance for Defendant Cook County by Silvia Mercado Masters (Masters, Silvia) (Entered: 03/05/2025)

ATTORNEY Appearance for Defendant Cook County by Jessica Wasserman (Wasserman, Jessica) (Entered: 03/05/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: In light of the motions to dismiss, the April 15, 2025 initial status hearing is stricken and no initial status report need be filed by April 8, 2025. The Court will set appropriate dates following its ruling on the pending motions. Mailed notice. (jlj, ) (Entered: 03/05/2025)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number AILNDC-23235065. (Gaiser, Thomas) (Entered: 03/20/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: Motion to appear pro hac vice 39 is granted. Mailed notice. (jlj, ) (Entered: 03/20/2025)

MOTION by Amicus State of Ohio for leave to file Brief of Amici Curiae (Gaiser, Thomas) (Entered: 03/21/2025)

ATTORNEY Appearance for Amicus Parties ACLU of Illinois, Illinois Coalition for Immigrant and Refugee Rights, Mujeres Latinas en Accion, National Immigrant Justice Center by Rebecca Kim Glenberg (Glenberg, Rebecca) (Entered: 03/25/2025)

ATTORNEY Appearance for Amicus Parties ACLU of Illinois, Illinois Coalition for Immigrant and Refugee Rights, Mujeres Latinas en Accion, National Immigrant Justice Center by Michelle Teresa Garcia (Garcia, Michelle) (Entered: 03/25/2025)

MOTION by Amicus Parties ACLU of Illinois, Illinois Coalition for Immigrant and Refugee Rights, Mujeres Latinas en Accion, National Immigrant Justice Center for leave to file Brief of Amici Curiae (Attachments: # 1 EXHIBIT A)(Glenberg, Rebecca) (Entered: 03/25/2025)

MOTION by Plaintiff United States of America for leave to file excess pages and leave to file a consolidated memorandum, MOTION by Plaintiff United States of America to set a briefing schedule for its anticipated cross-motion for summary judgment (Neylan, Elisabeth) (Entered: 03/28/2025)

MOTION by Amicus Parties Illinois Coalition for Immigrant and Refugee Rights, Illinois Coalition for Immigrant and Refugee Rights, Organized Communities Against Deportations, Raise the Floor AllianceMOTION FOR LEAVE TO FILE AN AMICI CURIAE BRIEF ON BEHALF OF BRIGHTON PARK NEIGHBORHOOD COUNCIL, ILLINOIS COALITION FOR IMMIGRANT AND REFUGEE RIGHTS, ORGANIZED COMMUNITIES AGAINST DEPORTATIONS AND RAISE THE FLOOR ALLIANCE (Attachments: # 1 Exhibit 1)(Bedi, Sheila) (Entered: 03/28/2025)

1 Exhibit 1

View on PACER

MINUTE entry before the Honorable Lindsay C. Jenkins: The motion for leave 46 is partly granted. The United States' forthcoming consolidated brief in response to the motions to dismiss may not exceed 45 pages. Defendants' replies remain due by April 29, 2025. The United States also anticipates filing a motion for summary judgment, but Defendants oppose this approach and have asked for an opportunity to explain their reasons. Any response from Defendants (ideally in a single consolidated filing representing all views) is due by April 4, 2025, and that filing should include an alternative briefing schedule to the one the United States has proposed. For now, no summary judgment motion should be filed so that the Court can take Defendants' positions into account and set the appropriate schedule thereafter. Mailed notice. (jlj, ) (Entered: 03/31/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: The motions for leave to file an amici curiae brief 41 44 45 are all granted. Any amici briefs by the moving entities are due no later than April 8, 2025. Those amici who attached their proposed briefs to their motions should file their briefs as a freestanding docket entry no later than April 8, 2025. Mailed notice. (jlj, ) (Entered: 03/31/2025)

Brief of Amici Curiae by ACLU of Illinois, Illinois Coalition for Immigrant and Refugee Rights, Mujeres Latinas en Accion, National Immigrant Justice Center (Glenberg, Rebecca) (Entered: 03/31/2025)

RESPONSE by United States of Americain Opposition to MOTION by Defendants State of Illinois, J. B. Pritzker to dismiss Rule 12(B) 24, MOTION by Defendant Cook County to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1) MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Cook County Pursuant to Rule 12(b)(6) 27, MOTION by Defendant Thomas Dart to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1) MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Thomas Dart Pursuant to Rule 12(b)(6) 31, MOTION by Defendants County Board of Commissioners, Toni Preckwinkle to dismiss for lack of jurisdiction Pursuant to Rule 12(b)(1) MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants County Board of Commissioners, Toni Preckwinkle Pursuant to Rule 12(b)(6) 29, MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants City Of Chicago, Brandon Johnson, Larry Snelling 33 (Neylan, Elisabeth) (Entered: 04/01/2025)

BRIEF OF AMICI CURIAE BRIGHTON PARK NEIGHBORHOOD COUNCIL, ILLINOIS COALITION FOR IMMIGRANT AND REFUGEE RIGHTS, ORGANIZED COMMUNITIES AGAINST DEPORTATIONS AND RAISE THE FLOOR ALLIANCE by Illinois Coalition for Immigrant and Refugee Rights, Organized Communities Against Deportations, Raise the Floor Alliance, Brighton Park Neighborhood Council (Bedi, Sheila) (Entered: 04/02/2025)

ENTERED IN ERROR (Entered: 04/03/2025)

RESPONSE by Defendants J. B. Pritzker, State of Illinois to order on motion for miscellaneous relief,,,, text entry,,, 47 Defendants' Combined Response re: Plaintiff's Request for Summary Judgment Briefing Schedule (Wells, Christopher) (Entered: 04/04/2025)

NOTICE by United States of America of Intent to File a Reply In Support of Motion to File a Consolidated Memorandum and to Set a Briefing Schedule, ECF No. 45 (Neylan, Elisabeth) (Entered: 04/07/2025)

BRIEF filed by State of Ohio and 22 Other States (Gaiser, Thomas) (Entered: 04/08/2025)

REPLY by United States of America to Response, 53, MOTION by Plaintiff United States of America for leave to file excess pages and leave to file a consolidated memorandum MOTION by Plaintiff United States of America to set a briefing schedule for its anticipated cross-motion for summary judgment 45 (Neylan, Elisabeth) (Entered: 04/08/2025)

MINUTE entry before the Honorable Lindsay C. Jenkins: In light of the United States' acknowledgement that the motion to file a consolidated brief is moot given that it has already filed its response to Defendants' motions to dismiss, see Dkt. 50; Dkt. 56 at 4 n.3, the motion for leave to file a consolidated memorandum and to set a briefing schedule for a cross-motion for summary judgment 45 is denied. The United States may file a cross-motion for summary judgment "at any time until 30 days after the close of all discovery." Fed. R. Civ. P. 56(b). Any motion it files must comply with Local Rule 56.1. However, the Court will not set a briefing schedule for summary judgment at this time given that the parties have not agreed on whether discovery is needed, and no discovery has taken place. Fed. R. Civ. P. 56(d) (explaining the court may allow parties time to "obtain affidavits or declarations or to take discovery"); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250 n.5 (1986) ("[S]ummary judgment [may] be refused where the nonmoving party has not had the opportunity to discover information that is essential to his opposition."). Defendants will have one week after any motion for summary judgment is filed to advise the Court, preferably through a single consolidated filing, as to their position on a briefing schedule and discovery in accordance with Rule 56(d). Defendants' replies in support of its motions to dismiss remain due by April 29, 2025. Mailed notice. (jlj, ) (Entered: 04/09/2025)

MOTION by Plaintiff United States of America for summary judgment (Neylan, Elisabeth) (Entered: 04/14/2025)

MEMORANDUM by United States of America in support of motion for summary judgment 58 (Neylan, Elisabeth) (Entered: 04/14/2025)

RULE 56 (c)(4) Statement by United States of America regarding motion for summary judgment 58 (Attachments: # 1 Declaration Declaration of Samuel J. Olson)(Neylan, Elisabeth) (Entered: 04/14/2025)

1 Declaration Declaration of Samuel J. Olson

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MINUTE entry before the Honorable Lindsay C. Jenkins: Defendants have until April 22, 2025 to advise the Court, preferably through a single consolidated filing, as to their position on a briefing schedule and discovery in light of the United States' motion for summary judgment. No replies are permitted unless the Court requests a reply. Mailed notice. (jlj, ) (Entered: 04/15/2025)