Case: International Union, United Automobile, Aerospace and Agricultural Implement Workers of America v. United States Department of State

COMPLAINT against All Defendants. (Filing Fee $ 405.00, Receipt Number ANYSDC-31858265)Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

CIVIL COVER SHEET filed..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to United States Department of State, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Marco Rubio, in his official capacity as Secretary of the U.S. Department of State, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to United States Department of Homeland Security, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Kristi Noem, in her official capacity as Secretary of the U.S. Department of Homeland Security, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Immigration and Customs Enforcement, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Todd Lyons, in his official capacity as Acting Director of U.S. Immigration and Customs Enforcement, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to United States Citizenship and Immigration Service, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to Joseph B. Edlow, in his official capacity as Director of U.S. Citizenship and Immigration Service, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

REQUEST FOR ISSUANCE OF SUMMONS as to United States of America, re: 1 Complaint,. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Langford, John) (Entered: 10/16/2025)

NOTICE OF APPEARANCE by Tobin Raju on behalf of American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Raju, Tobin) (Entered: 10/16/2025)

NOTICE OF APPEARANCE by Stacy Livingston on behalf of American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)..(Livingston, Stacy) (Entered: 10/16/2025)

NOTICE OF APPEARANCE OF PRO BONO COUNSEL by Golnaz Fakhimi on behalf of American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW).(Fakhimi, Golnaz) (Entered: 10/16/2025)

COMPLAINT against Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America..(Langford, John) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to United States Department of State. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to Marco Rubio. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to United States Department of Homeland Security. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to Kristi Noem. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to United States Immigration and Customs Enforcement. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to United States Citizenship and Immigration Service. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to Joseph B. Edlow. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to Todd Lyons. (vf) (Entered: 10/17/2025)

ELECTRONIC SUMMONS ISSUED as to United States of America, U.S. Attorney and U.S. Attorney General. (vf) (Entered: 10/17/2025)

***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney John Langford. The party information for the following party/parties has been modified: International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), Marco Rubio, Kristi Noem, Joseph B. Edlow, Todd Lyons. The information for the party/parties has been modified for the following reason/reasons: party text was omitted; party name entered incorrectly. (vf)

Case Opening Initial Assignment Notice

Notice to Attorney Regarding Deficient Pleading

Notice to Attorney Regarding Party Modification

***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney John Langford to RE-FILE Document No. 1 Complaint. The filing is deficient for the following reason(s): the All Defendant radio button was selected. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (vf)

CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Alvin K. Hellerstein. Please download and review the Individual Practices of the assigned District Judge, located at https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at https://nysd.uscourts.gov/rules/ecf-related-instructions..(vf)

Magistrate Judge Sarah Netburn is designated to handle matters that may be referred in this case. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vf)

Case Designated ECF. (vf)

MOTION for David Greene to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32006405. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit Local Rule 1.3 Declaration, # 2 Supplement Certificate of Good Standing, # 3 Proposed Order Granting PHV Motion).(Greene, David) (Entered: 11/17/2025)

ORDER granting 25 Motion for David Greene to Appear Pro Hac Vice. The motion of David Greene for admission to practice Pro Hac Vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are Subject to the Local Rules of this Court including the Rules governing discipline of attorneys. (Signed by Judge Alvin K. Hellerstein on 11/18/25) (yv) (Entered: 11/18/2025)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 25 MOTION for David Greene to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32006405. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

Notice Regarding Pro Hac Vice Motion

AFFIDAVIT OF SERVICE. Joseph B. Edlow served on 10/28/2025, answer due 12/29/2025; Todd Lyons served on 10/28/2025, answer due 12/29/2025; Kristi Noem served on 10/28/2025, answer due 12/29/2025; Marco Rubio served on 10/28/2025, answer due 12/29/2025; United States Citizenship and Immigration Service served on 10/28/2025, answer due 12/29/2025; United States Department of Homeland Security served on 10/28/2025, answer due 12/29/2025; United States Department of State served on 10/28/2025, answer due 12/29/2025; United States Immigration and Customs Enforcement served on 10/28/2025, answer due 12/29/2025; United States of America served on 10/28/2025, answer due 12/29/2025. Service was made by MAIL. Document filed by American Federation of Teachers; Communications Workers of America; International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit of Service for United States Department of State, # 2 Affidavit of Service for Marco Rubio, # 3 Affidavit of Service for United States Department of Homeland Security, # 4 Affidavit of Service for Kristi Noem, # 5 Affidavit of Service for United States Citizenship and Immigration Service, # 6 Affidavit of Service for Joseph B. Edlow, # 7 Affidavit of Service for United States Immigration and Customs Enforcement, # 8 Affidavit of Service for Todd Lyons, # 9 Affidavit of Service for United States of America, # 10 Affidavit of Service for United States Attorney for the Southern District of New York).(Langford, John) (Entered: 11/19/2025)

MOTION for Sophia Cope to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32022398. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit Local Rule 1.3 Declaration, # 2 Supplement Certificate of Good Standing, # 3 Proposed Order Granting PHV Motion).(Cope, Sophia) (Entered: 11/19/2025)

ORDER granting 28 Motion for Sophia Cope to Appear Pro Hac Vice. The motion of Sophia Cope for admission to practice Pro Hac Vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are Subject to the Local Rules of this Court including the Rules governing discipline of attorneys. (Signed by Judge Alvin K. Hellerstein on 11/20/25) (yv) (Entered: 11/20/2025)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 28 MOTION for Sophia Cope to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32022398. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

Notice Regarding Pro Hac Vice Motion

NOTICE OF APPEARANCE by Jennifer Ann Jude on behalf of Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America..(Jude, Jennifer) (Entered: 11/26/2025)

MOTION for Elizabeth Femia to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32055838. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit Local Rule 1.3 Declaration, # 2 Supplement CA Certificate of Good Standing, # 3 Supplement DC Certificate of Good Standing, # 4 Supplement NY Certificate of Good Standing, # 5 Proposed Order Granting PHV Motion).(Femia, Elizabeth) (Entered: 11/26/2025)

ORDER granting 31 Motion for Elizabeth Femia to Appear Pro Hac Vice. The motion of Elizabeth Femia for admission to practice Pro Hac Vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are Subject to the Local Rules of this Court including the Rules governing discipline of attorneys. (Signed by Judge Alvin K. Hellerstein on 12/1/2025) (jjc) (Entered: 12/01/2025)

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 31 MOTION for Elizabeth Femia to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32055838. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (rju)

Notice Regarding Pro Hac Vice Motion

CONSENT LETTER MOTION for Extension of Time to File Response/Reply as to 15 Complaint, and Set Briefing Schedule addressed to Judge Alvin K. Hellerstein from Jennifer Jude dated 12/12/25. Document filed by Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America..(Jude, Jennifer) (Entered: 12/12/2025)

ORDER granting 33 Letter Motion for Extension of Time to File Response/Reply. So ordered. ( Responses due by 2/4/2026 Replies due by 2/18/2026.) (Signed by Judge Alvin K. Hellerstein on 12/12/25) (yv) (Entered: 12/12/2025)

Set/Reset Deadlines: Joseph B. Edlow answer due 1/14/2026; Todd Lyons answer due 1/14/2026; Kristi Noem answer due 1/14/2026; Marco Rubio answer due 1/14/2026; United States Citizenship and Immigration Service answer due 1/14/2026; United States Department of Homeland Security answer due 1/14/2026; United States Department of State answer due 1/14/2026; United States Immigration and Customs Enforcement answer due 1/14/2026; United States of America answer due 1/14/2026. Motions due by 2/18/2026. (yv)

CONSENT LETTER MOTION for Extension of Time to Respond to Complaint addressed to Judge Alvin K. Hellerstein from Jennifer Jude dated 1/12/26. Document filed by Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America..(Jude, Jennifer) (Entered: 01/12/2026)

ORDER granting 35 Letter Motion for Extension of Time. So Ordered. I approve the schedule. Amended Pleadings due by 3/6/2026. Motions due by 3/20/2026. (Signed by Judge Alvin K. Hellerstein on 1/13/2026) (tg) (Entered: 01/13/2026)

Set/Reset Deadlines: Responses due by 3/6/2026 Replies due by 3/20/2026. (tg)

Set/Reset Deadlines: Joseph B. Edlow answer due 2/13/2026; Todd Lyons answer due 2/13/2026; Kristi Noem answer due 2/13/2026; Marco Rubio answer due 2/13/2026; United States Citizenship and Immigration Service answer due 2/13/2026; United States Department of Homeland Security answer due 2/13/2026; United States Department of State answer due 2/13/2026; United States Immigration and Customs Enforcement answer due 2/13/2026; United States of America answer due 2/13/2026. Motions due by 2/13/2026. (tg)

MOTION for Saira Hussain to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32267874. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit Local Rule 1.3 Declaration, # 2 Supplement CA Certificate of Good Standing, # 3 Proposed Order Granting PHV Motion).(Hussain, Saira) (Entered: 01/15/2026)

ORDER granting 37 Motion for Saira Hussain to Appear Pro Hac Vice. The motion of Saira Hussain for admission to practice Pro Hac Vice in the above-captioned action is granted. IT IS HEREBY ORDERED that Applicant is admitted Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are Subject to the Local Rules of this Court including the Rules governing discipline of attorneys. (Signed by Judge Alvin K. Hellerstein on 1/15/26) (yv) (Entered: 01/15/2026)

Notice Regarding Pro Hac Vice Motion

>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 37 MOTION for Saira Hussain to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-32267874. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bc)

MOTION for Tobin Raju to Withdraw as Attorney . Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Affidavit Affidavit of Tobin Raju in support of Motion to Withdraw as counsel).(Raju, Tobin) (Entered: 01/16/2026)

Set/Reset Deadlines: Responses due by 3/13/2026. Replies due by 3/27/2026. (yv)

MEMORANDUM OF LAW in Opposition re: 51 MOTION to Dismiss the First Amended Complaint. . Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America..(Langford, John) (Entered: 04/22/2026)

MOTION for Golnaz Fakhimi to Withdraw as Attorney . Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America..(Fakhimi, Golnaz) (Entered: 04/24/2026)

MEMO ENDORSED ORDER granting 59 Motion to Withdraw as Attorney. ENDORSEMENT: So ordered. ( Attorney Golnaz Fakhimi terminated.) (Signed by Judge Alvin K. Hellerstein on 4/27/26) (yv) (Entered: 04/27/2026)

MOTION to File Amicus Brief in Support of Plaintiffs. Document filed by Thirty Labor Scholars. (Attachments: # 1 Exhibit Brief of Labor Scholars as Amici Curiae, # 2 Exhibit Proposed Order Granting Leave to File Amicus Brief).(Mansoor, Hafsa) (Entered: 04/27/2026)

1 Exhibit Brief of Labor Scholars as Amici Curiae

View on PACER

2 Exhibit Proposed Order Granting Leave to File Amicus Brief

View on PACER

MOTION to Supplement the First Amended Complaint Pursuant to Federal Rule of Civil Procedure 15(d) . Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America..(Langford, John) (Entered: 04/29/2026)

MEMORANDUM OF LAW in Support re: 62 MOTION to Supplement the First Amended Complaint Pursuant to Federal Rule of Civil Procedure 15(d) . . Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit 1. Clean Proposed Supplemented Amended Complaint, # 2 Exhibit 2. Redlined Proposed Supplemented Amended Complaint).(Langford, John) (Entered: 04/29/2026)

1

View on RECAP

2

View on RECAP

CONSENT LETTER MOTION for Extension of Time to File Reply Brief addressed to Judge Alvin K. Hellerstein from Jennifer Jude dated 4/30/26., CONSENT LETTER MOTION for Leave to File Excess Pages or for Clarification regarding Application of Local Civil Rule 7.1 addressed to Judge Alvin K. Hellerstein from Jennifer Jude dated 4/30/26. Document filed by Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America..(Jude, Jennifer) (Entered: 04/30/2026)

LETTER addressed to Judge Alvin K. Hellerstein from John Langford dated 05/04/2026 re: Supplemental Authority Relevant to the Government's Motion to Dismiss the Amended Complaint. Document filed by American Federation of Teachers, Communications Workers of America, International Union, United Automobile, Aerospace and Agricultural Implement Workers of America. (Attachments: # 1 Exhibit First Choice Women's Resource Centers, Inc. v. Davenport, No. 24-781 (U.S. Apr. 29, 2026)).(Langford, John) (Entered: 05/04/2026)

1

View on RECAP

CONSENT LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Alvin K. Hellerstein from Jennifer Jude dated 5/10/26. Document filed by Joseph B. Edlow, Todd Lyons, Kristi Noem, Marco Rubio, United States Citizenship and Immigration Service, United States Department of Homeland Security, United States Department of State, United States Immigration and Customs Enforcement, United States of America..(Jude, Jennifer) (Entered: 05/10/2026)

ORDER granting 66 Letter Motion for Extension of Time to File Response/Reply. So ordered. ( Replies due by 5/14/2026.) (Signed by Judge Alvin K. Hellerstein on 5/11/26) (yv) (Entered: 05/11/2026)

ORDER GRANTING MOTION TO SUPPLEMENT COMPLAINT granting 62 Motion. Plaintiffs move under Federal Rule of Civil Procedure 15(d) and Local Civil Rule 15.1 to supplement their first amended complaint. Finding that Plaintiffs' proposed revisions are narrowly drafted, made in good faith, and will not prejudice Defendants, I grant the motion. Plaintiffs shall file the supplemented first amended complaint as proposed. The grant of this motion does not alter the briefing schedule on the motion to dismiss. SO ORDERED. (Signed by Judge Alvin K. Hellerstein on 5/14/2026) (tg) (Entered: 05/14/2026)

ORDER granting 61 Motion to File Amicus Brief. Upon consideration of the Unopposed Motion by Labor Scholars for Leave to File an Amicus Brief in Support of Plaintiffs, it is hereby: ORDERED that the Motion is GRANTED, and Exhibit 1 to the Motion shall be docketed by the Clerk of the Court. (Signed by Judge Alvin K. Hellerstein on 5/14/2026) (tg) (Entered: 05/14/2026)

BRIEF OF LABOR SCHOLARS AS AMICI CURIAE. Document filed by Emery Celli Brinckerhoff.(tg) (Entered: 05/14/2026)

Amended Complaint

Reply Memorandum of Law in Support of Motion