Case: Padres Unidos de Tulsa v. Drummond

5:24-cv-00526 | U.S. District Court for the Western District of Oklahoma

Filed Date: May 23, 2024

Closed Date: June 5, 2024

Clearinghouse coding complete

Case Summary

This case is a challenge to Oklahoma House Bill 4156 (“H.B. 4156”), which created the crime of "impermissible occupation" and allowed law enforcement in Oklahoma to arrest people for being in the U.S. without legal authorization.  ​In April 2024, Oklahoma enacted House Bill 4156 (H.B. 4156), introducing the crime of "impermissible occupation," which authorized state and local law enforcement to arrest individuals suspected of being in the United States without legal authorization. The law did n…

This case is a challenge to Oklahoma House Bill 4156 (“H.B. 4156”), which created the crime of "impermissible occupation" and allowed law enforcement in Oklahoma to arrest people for being in the U.S. without legal authorization. 

​In April 2024, Oklahoma enacted House Bill 4156 (H.B. 4156), introducing the crime of "impermissible occupation," which authorized state and local law enforcement to arrest individuals suspected of being in the United States without legal authorization. The law did not provide a defense for people currently seeking asylum, other humanitarian protection, or any other relief available under federal law. 

On May 23, 2024, Padres Unidos de Tulsa, a membership-based advocacy organization comprising students, parents, and teachers, along with an individual plaintiff, filed a lawsuit in the U.S. District Court for the Western District of Oklahoma challenging H.B. 4156. The plaintiffs were represented by the American Civil Liberties Union (ACLU), the ACLU of Oklahoma, the National Immigration Law Center, and the private counsel. The defendants included Oklahoma Attorney General, Tulsa County District Attorney, Oklahoma County District Attorney, and Public Safety Commissioner. Plaintiffs filed suit 42 U.S.C. § 1983, alleging that H.B. 4156 violated the Supremacy Clause and Commerce Clause of the U.S. Constitution, as well as the Eighth and Fourteenth Amendments. Plaintiffs sought declaratory and injunctive relief to enjoin Defendants from enforcing H.B. 4156, and attorneys' fees. 

On Count I, Plaintiffs alleged that H.B. 4156 violated the Supremacy Clause because it attempted to regulate immigration – a matter exclusively reserved for the federal government. Further, H.B. 4156 further violated the Supremacy Clause because it conflicted with federal laws. 

On Count II, Plaintiffs alleged that H.B. 4156 violated the Commerce Clause because it impermissibly regulated people’s entry into Oklahoma and their movement across state and national borders, posing unacceptable burdens on interstate and foreign commerce. 

On Count III, Plaintiffs alleged that H.B. 4156 violated the Eighth Amendment because it required noncitizens convicted of state illegal entry or state illegal reentry to leave the State within seventy two hours of their conviction or release from custody, resulting in their banishment from the State and constituting cruel and unusual punishment. 

The case was assigned to Judge David L. Russell and later reassigned to Judge Bernard M. Jones.

The following day, Plaintiffs filed an amended complaint, adding additional individual plaintiffs who would face “severe hardship”  detained or removed under H.B. 4156.

On May 24, 2024, Plaintiffs filed a motion for a preliminary injunction to halt the implementation of H.B. 4156 while the case was adjudicated. 

Subsequently, the case was consolidated with a similar lawsuit, United States v. Oklahoma 5:24-cv-00511 (W.D. Okla.), a lawsuit brought by the Biden administration also challenging the constitutionality of H.B. 4156. 

The Trump administration moved to dismiss the consolidated cases on March 14, 2025. A final order is pending. 

Summary Authors

Madilynn O'Hara (4/5/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/68561192/parties/padres-unidos-de-tulsa-v-drummond/


Judge(s)

Jones, Bernard M. (Oklahoma)

Attorney for Plaintiff

Amdur, Spencer Elijah (Oklahoma)

Awasthi, Devraat (Oklahoma)

Jadwat, Omar (Oklahoma)

Attorney for Defendant

Gaskins, Garry M (Oklahoma)

show all people

Documents in the Clearinghouse

Document
1

5:24-cv-00526

Complaint for Declaratory, Injunctive, and Other Relief

May 23, 2024

May 23, 2024

Complaint
14

5:24-cv-00526

Amended Complaint for Declaratory, Injunctive, and Other Relief

May 24, 2024

May 24, 2024

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/68561192/padres-unidos-de-tulsa-v-drummond/

Last updated April 21, 2025, 2:55 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Vicki Behenna, Gentner Drummond, Steve Kunzweiler, Tim Tipton filed by Padres Unidos de Tulsa, Ximena Monserrat Lopez Mena. (Attachments: # 1 Civil Cover Sheet)(ekw) (Entered: 05/23/2024)

1 Civil Cover Sheet

View on PACER

May 23, 2024

May 23, 2024

Clearinghouse

Payment for a Civil Case

May 23, 2024

May 23, 2024

PACER
2

Summons Issued Electronically as to Vicki Behenna, Gentner Drummond, Steve Kunzweiler, Tim Tipton. (ekw) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
3

NOTICE OF RELATED OR COMPANION CASE by All Plaintiffs (Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
4

ENTRY of Appearance by Elissa Stiles on behalf of All Plaintiffs (Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER

PAYMENT FOR A CIVIL CASE Filing fee $ 405, receipt number AOKWDC-4440170. (Stiles, Elissa)

May 23, 2024

May 23, 2024

PACER
5

MOTION for Leave to Appear Pro Hac Vice for Noor Zafar Filing fee $ 100, receipt number AOKWDC-4440173 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
6

MOTION for Leave to Appear Pro Hac Vice for Omar Jadwat Filing fee $ 100, receipt number AOKWDC-4440174 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
7

MOTION for Leave to Appear Pro Hac Vice for Wafa Junaid Filing fee $ 100, receipt number AOKWDC-4440178 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
8

MOTION for Leave to Appear Pro Hac Vice for Spencer Amdur Filing fee $ 100, receipt number AOKWDC-4440183 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
9

MOTION for Leave to Appear Pro Hac Vice for Oscar Sarabia Roman Filing fee $ 100, receipt number AOKWDC-4440186 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
10

MOTION for Leave to Appear Pro Hac Vice for Cody Wofsy Filing fee $ 100, receipt number AOKWDC-4440188 by All Plaintiffs. (Attachments: # 1 Attachment PHV Application Form)(Stiles, Elissa) (Entered: 05/23/2024)

May 23, 2024

May 23, 2024

PACER
11

ENTRY of Appearance by Devraat Awasthi on behalf of All Plaintiffs (Awasthi, Devraat) Document flattened to optimize CM/ECF display; no other changes made . Modified on 5/24/2024 (naa). (Entered: 05/24/2024)

May 24, 2024

May 24, 2024

PACER
12

ENTRY of Appearance by Megan E Lambert on behalf of All Plaintiffs (Lambert, Megan) Document flattened to optimize CM/ECF display; no other changes made . Modified on 5/24/2024 (naa). (Entered: 05/24/2024)

May 24, 2024

May 24, 2024

PACER
13

ENTER ORDER REASSIGNING CASE: Case reassigned to Judge Bernard M. Jones for all further proceedings. Judge David L. Russell no longer assigned to case. Entered at the direction of Judge David L. Russell on 05/24/2024. (km) (Entered: 05/24/2024)

May 24, 2024

May 24, 2024

PACER
14

AMENDED COMPLAINT against All Defendants filed by All Plaintiffs.(Stiles, Elissa) (Entered: 05/24/2024)

May 24, 2024

May 24, 2024

Clearinghouse
15

MOTION for Preliminary Injunction by All Plaintiffs. (Attachments: # 1 Exhibit Declaration of Ximena Monserrat Lopez Mena, # 2 Exhibit Declaration of Jordy Madrigal Martinez, # 3 Exhibit Declaration of Antonio Marquez, # 4 Exhibit Rene Doroteo Hernandez, # 5 Exhibit Declaration of Michelle Lara, # 6 Exhibit Declaration of M.A.)(Stiles, Elissa) (Entered: 05/24/2024)

1 Exhibit Declaration of Ximena Monserrat Lopez Mena

View on PACER

2 Exhibit Declaration of Jordy Madrigal Martinez

View on PACER

3 Exhibit Declaration of Antonio Marquez

View on PACER

4 Exhibit Rene Doroteo Hernandez

View on PACER

5 Exhibit Declaration of Michelle Lara

View on PACER

6 Exhibit Declaration of M.A.

View on PACER

May 24, 2024

May 24, 2024

PACER
16

SUMMONS Returned Executed by Padres Unidos de Tulsa, Ximena Monserrat Lopez Mena. Gentner Drummond served on 5/24/2024. (Attachments: # 1 Exhibit Summons Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
17

SUMMONS Returned Executed by Padres Unidos de Tulsa, Ximena Monserrat Lopez Mena. Tim Tipton served on 5/24/2024. (Attachments: # 1 Exhibit Summons Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
18

SUMMONS Returned Executed by Padres Unidos de Tulsa, Ximena Monserrat Lopez Mena. Steve Kunzweiler served on 5/24/2024. (Attachments: # 1 Exhibit Summons Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
19

SUMMONS Returned Executed by Padres Unidos de Tulsa, Ximena Monserrat Lopez Mena. Vicki Behenna served on 5/24/2024. (Attachments: # 1 Exhibit Summons Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
20

RETURN OF SERVICE - NON SUMMONS Amended Complaint and Motion for Preliminary Injunction - Drummond by Ximena Monserrat Lopez Mena, Padres Unidos de Tulsa (Attachments: # 1 Exhibit Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
21

RETURN OF SERVICE - NON SUMMONS Amended Complaint and Motion for Preliminary Injunction - Tipton by Ximena Monserrat Lopez Mena, Padres Unidos de Tulsa (Attachments: # 1 Exhibit Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
22

RETURN OF SERVICE - NON SUMMONS Amended Complaint and Motion for Preliminary Injunction - Kunzweiler by Ximena Monserrat Lopez Mena, Padres Unidos de Tulsa (Attachments: # 1 Exhibit Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
23

RETURN OF SERVICE - NON SUMMONS Amended Complaint and Motion for Preliminary Injunction - Behenna by Ximena Monserrat Lopez Mena, Padres Unidos de Tulsa (Attachments: # 1 Exhibit Affidavit of Service)(Stiles, Elissa) (Entered: 05/31/2024)

May 31, 2024

May 31, 2024

PACER
24

ORDER ~ Granting [5-10] Motion to Appear Pro Hac Vice. Noor Zafar, Omar Jadwat, Wafa Junaid, Spencer Amdur, Oscar Sarabia Roman, and Cody Wofsy are hereby admitted to practice before this Court for the limited purpose of participating in this case. Signed by Judge Bernard M. Jones on 6/3/2024. (dwl) (Entered: 06/03/2024)

June 3, 2024

June 3, 2024

PACER
25

ENTRY of Appearance by Noor Zafar on behalf of All Plaintiffs (Zafar, Noor) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
26

ENTRY of Appearance by Spencer Elijah Wittmann Amdur on behalf of All Plaintiffs (Amdur, Spencer) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
27

ENTRY of Appearance by Oscar Sarabia Roman on behalf of All Plaintiffs (Sarabia Roman, Oscar) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
28

ENTRY of Appearance by Wafa Junaid on behalf of All Plaintiffs (Junaid, Wafa) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
29

ENTRY of Appearance by Cody Wofsy on behalf of All Plaintiffs (Wofsy, Cody) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
30

ENTRY of Appearance by Omar Jadwat on behalf of All Plaintiffs (Jadwat, Omar) (Entered: 06/04/2024)

June 4, 2024

June 4, 2024

PACER
31

ENTRY of Appearance by Garry M Gaskins, II on behalf of Vicki Behenna, Gentner Drummond, Steve Kunzweiler, Tim Tipton (Gaskins, Garry) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

PACER
32

ENTRY of Appearance by Zachary P West on behalf of Vicki Behenna, Gentner Drummond, Steve Kunzweiler, Tim Tipton (West, Zachary) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

PACER
33

NOTICE OF PENDING MOTIONS by All Defendants (Attachments: # 1 Exhibit A - Defs' Unopposed Mtn to Consolidate - US v. OK 24-cv-511)(West, Zachary) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

PACER
34

UNOPPOSED MOTION for Extension of Time to File Answer re 14 Amended Complaint by All Defendants. (Attachments: # 1 Attachment Proposed Order for Mtn to Stay)(West, Zachary) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

PACER
35

JOINT MOTION to Extend Deadlines or Hearings by All Defendants. (Attachments: # 1 Attachment Proposed Order - Mtn Joint Briefing Schedule)(West, Zachary) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

PACER
36

ORDER ~ Defendants' Unopposed Motion for a Stay of Their Deadline to Respond to the Complaint 34 is GRANTED. The Court will set any deadlines for responding to the complaint after ruling on Plaintiffs' pending motion for injunctive relief. Joint Motion for Briefing Schedule 35 is GRANTED, as more fully set out in the Order. Signed by Judge Bernard M. Jones on 6/5/2024. (dwl) (Entered: 06/05/2024)

June 5, 2024

June 5, 2024

RECAP

Case Details

State / Territory: Oklahoma

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Trump Administration 2.0: Litigation and Investigations Involving the Government

Trump Administration 2.0: Litigation and Investigations Involving the Government (Immigration Enforcement)

Key Dates

Filing Date: May 23, 2024

Closing Date: June 5, 2024

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Los Padres Unidos, a membership-based advocacy organization comprising students, parents, and teachers, and several individual residents in Oklahoma

Plaintiff Type(s):

Private Plaintiff

Non-profit NON-religious organization

Attorney Organizations:

ACLU Affiliates (any)

National Immigration Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Oklahoma Attorney General, State

Tulsa County District Attorney (Tulsa), County

Oklahoma County District Attorney (Oklahoma), County

Public Safety Commissioner, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Commerce Power

Due Process: Procedural Due Process

Due Process: Substantive Due Process

Equal Protection

Cruel and Unusual Punishment

Supremacy Clause

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

Discrimination Basis:

Immigration status

Affected National Origin/Ethnicity(s):

Hispanic

Immigration/Border:

Constitutional rights

Deportation - criteria

Deportation - judicial review

Deportation - procedure

Refugees

Undocumented immigrants - rights and duties

Undocumented immigrants - state and local regulation