Case: City and County of San Francisco v. Sessions

4:18-cv-02068 | U.S. District Court for the Northern District of California

Filed Date: April 5, 2018

Closed Date: May 20, 2019

Clearinghouse coding complete

Case Summary

City Attorneys from the City and County of San Francisco (the City) filed this suit on April 5, 2018, challenging the Department of Justice's (DOJ) bulk rescission of documents that provided guidance of the DOJ's interpretation of laws protecting various groups of people. In so doing, the City argued that the DOJ undermined civil rights protections for marginalized communities and undermined regulated entities like the City from being able to effectively comply with federal law. The City argued…

City Attorneys from the City and County of San Francisco (the City) filed this suit on April 5, 2018, challenging the Department of Justice's (DOJ) bulk rescission of documents that provided guidance of the DOJ's interpretation of laws protecting various groups of people. In so doing, the City argued that the DOJ undermined civil rights protections for marginalized communities and undermined regulated entities like the City from being able to effectively comply with federal law. The City argued that the DOJ did not provide a meaningful reason for the rescission, in violation of the Administrative Procedure Act (APA). The City sought declaratory and injunctive relief. The case was filed in the U.S. District Court for the Northern District of California and assigned to Magistrate Judge Donna M. Ryu.

The City argued that these documents provided guidance to various regulated entities and "helped to protect civil rights of marginalized individuals," including "immigrants, the poor, people of color, and people with disabilities." The City argued that the reason given for the rescission was a press release that merely stated the documents were "unnecessary, inconsistent with existing law, or otherwise improper." The City argued this reasoning was conclusory and lacked particularized justifications for specific documents. While some parts of the DOJ website explain the withdrawal of particular documents, the City argued that the DOJ did not provide justification for withdrawing six particularly important documents. These six documents included guidance for state and local governments regarding removing unlawful juvenile offender fees, discrimination protection for disabled individuals, and discrimination protection under the Immigration and Nationality Act. The complaint highlighted that this rescission occurred in the context of a DOJ guided under Attorney Jefferson Sessions that "has shown a shocking disregard for protecting the rights of vulnerable communities, rolling back civil rights initiatives in a wide variety of areas."

The case has been assigned to Magistrate Judge Donna M. Ryu. It was reassigned to Judge Jon S. Tigar on June 14, 2018.

The Justice Department filed a motion to dismiss on June 18, 2018, but Judge Tiger determined this motion to be moot on August 1, 2018, when the plaintiffs filed an amended complaint. This new complaint maintained the APA causes of action from the first complaint, but added an additional rescission of DOJ documents in July 2018 to the facts of the case and modified the plaintiff's argument for standing.

After the plaintiffs filed the amended complaint, the DOJ filed an additional motion to dismiss on September 27, 2018. Judge Tigar granted the motion to dismiss on December 10, 2018. He wrote that the plaintiffs did not plead a particularized enough injury in order to have standing under the APA, and that municipalities are not subject to reduced pleading requirements like states are in APA claims. He added that regulatory or economic uncertainty was not enough for a municipality to have standing; the injury must be imminent or the municipality must have a plan or process in place to violate the new rule in order for it to have standing.

The plaintiffs did not appeal the ruling, and the case closed.

Summary Authors

Virginia Weeks (4/9/2018)

Virginia Weeks (6/30/2018)

Ellen Aldin (6/3/2020)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6906301/parties/city-and-county-of-san-francisco-v-whitaker/


Judge(s)
Attorney for Plaintiff

Eisenberg, Sara J. (California)

Flynn, Ronald P. (California)

Herrera, Dennis J. (California)

Lee, Mollie M. (California)

Attorney for Defendant

Lopez-Morales, Cesar A (District of Columbia)

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Documents in the Clearinghouse

Document

4:18-cv-02068

Docket [PACER]

City and County of San Francisco v. Whitaker

Feb. 20, 2019

Feb. 20, 2019

Docket
1

4:18-cv-02068

Complaint for Declaratory and Injunctive Relief

April 5, 2018

April 5, 2018

Complaint
30

4:18-cv-02068

First Amended Complaint for Declaratory and Injunctive Relief

July 30, 2018

July 30, 2018

Complaint
42

4:18-cv-02068

Order Granting Motion to Dismiss

City and County of San Francisco v. Whitaker

Dec. 10, 2018

Dec. 10, 2018

Order/Opinion

357 F.Supp.3d 357

Docket

See docket on RECAP: https://www.courtlistener.com/docket/6906301/city-and-county-of-san-francisco-v-whitaker/

Last updated April 8, 2024, 3:11 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT for Declaratory and Injunctive Relief against All Defendants ( Filing fee $ 400, receipt number 0971-12248551.). Filed byCity and County of San Francisco. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Civil Cover Sheet)(Herrera, Dennis) (Filed on 4/5/2018) (Entered: 04/05/2018)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Civil Cover Sheet

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April 5, 2018

April 5, 2018

Clearinghouse
2

Proposed Summons. (Herrera, Dennis) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
3

Case assigned to Magistrate Judge Donna M. Ryu. Counsel for plaintiff or the removing party is responsible for serving the Complaint or Notice of Removal, Summons and the assigned judge's standing orders and all other new case documents upon the opposing parties. For information, visit E-Filing A New Civil Case at http://cand.uscourts.gov/ecf/caseopening.Standing orders can be downloaded from the court's web page at www.cand.uscourts.gov/judges. Upon receipt, the summons will be issued and returned electronically. Counsel is required to send chambers a copy of the initiating documents pursuant to L.R. 5-1(e)(7). A scheduling order will be sent by Notice of Electronic Filing (NEF) within two business days. Consent/Declination due by 4/19/2018. (srnS, COURT STAFF) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
4

NOTICE of Appearance by Ronald P. Flynn Notice of Appearance of Counsel (Flynn, Ronald) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
5

NOTICE of Appearance by Yvonne Rosil Mere Notice of Appearance of Counsel (Mere, Yvonne) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
6

NOTICE of Appearance by Sara Jennifer Eisenberg Notice of Appearance of Counsel (Eisenberg, Sara) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
7

NOTICE of Appearance by Mollie M Lee Notice of Appearance of Counsel (Lee, Mollie) (Filed on 4/5/2018) (Entered: 04/05/2018)

April 5, 2018

April 5, 2018

PACER
8

Summons Issued as to Jefferson B. Sessions, III, United States Department of Justice, and U.S. Attorney General. (jjbS, COURT STAFF) (Filed on 4/6/2018) Modified on 4/9/2018 (cjlS, COURT STAFF). (Entered: 04/06/2018)

April 6, 2018

April 6, 2018

PACER
9

Initial Case Management Scheduling Order with ADR Deadlines: Case Management Statement due by 7/11/2018. Initial Case Management Conference set for 7/18/2018 01:30 PM in Oakland, Courtroom 4, 3rd Floor. (jjbS, COURT STAFF) (Filed on 4/6/2018) (Entered: 04/06/2018)

April 6, 2018

April 6, 2018

PACER
10

CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by City and County of San Francisco.. (Eisenberg, Sara) (Filed on 4/19/2018) (Entered: 04/19/2018)

April 19, 2018

April 19, 2018

PACER
11

Proof of Service by City and County of San Francisco (Eisenberg, Sara) (Filed on 4/20/2018) Modified on 4/23/2018 (jjbS, COURT STAFF). (Entered: 04/20/2018)

April 20, 2018

April 20, 2018

PACER
12

Updated Proof of Service by City and County of San Francisco (Eisenberg, Sara) (Filed on 5/24/2018) Modified on 5/25/2018 (jjbS, COURT STAFF). (Entered: 05/24/2018)

May 24, 2018

May 24, 2018

PACER
13

NOTICE of Appearance by Cesar A. Lopez-Morales on behalf of Defendants (Lopez-Morales, Cesar) (Filed on 6/12/2018) (Entered: 06/12/2018)

June 12, 2018

June 12, 2018

PACER
14

CONSENT/DECLINATION to Proceed Before a US Magistrate Judge by Jefferson B. Sessions, III, United States Department of Justice.. (Lopez-Morales, Cesar) (Filed on 6/12/2018) (Entered: 06/12/2018)

June 12, 2018

June 12, 2018

PACER

Electronic filing error. Re: 13 Notice of Appearance filed by United States Department of Justice, Jefferson B. Sessions, III. REMINDER TO COUNSEL: Counsel is instruct ed that all future filings shall bear the initials DMR immediately after the case number. (jjbS, COURT STAFF) (Filed on 6/13/2018)

June 13, 2018

June 13, 2018

PACER
15

CLERK'S NOTICE OF IMPENDING REASSIGNMENT TO A U.S. DISTRICT COURT JUDGE: The Clerk of this Court will now randomly reassign this case to a District Judge because either (1) a party has not consented to the jurisdiction of a Magistrate Judge, or (2) time is of the essence in deciding a pending judicial action for which the necessary consents to Magistrate Judge jurisdiction have not been secured. You will be informed by separate notice of the district judge to whom this case is reassigned. ALL HEARING DATES PRESENTLY SCHEDULED BEFORE THE CURRENT MAGISTRATE JUDGE ARE VACATED AND SHOULD BE RE-NOTICED FOR HEARING BEFORE THE JUDGE TO WHOM THIS CASE IS REASSIGNED. This is a text only docket entry; there is no document associated with this notice. (ig, COURT STAFF) (Filed on 6/13/2018) (Entered: 06/13/2018)

June 13, 2018

June 13, 2018

PACER
16

ORDER REASSIGNING CASE. Case reassigned to Judge Jon S. Tigar for all further proceedings. Judge Donna M. Ryu no longer assigned to the case. This case is assigned to a judge who participates in the Cameras in the Courtroom Pilot Project. See General Order 65 and http://cand.uscourts.gov/cameras. Signed by Executive Committee on 6/14/2018. (Attachments: # 1 Notice of Eligibility for Video Recording)(jmlS, COURT STAFF) (Filed on 6/14/2018) (Entered: 06/14/2018)

1 Notice of Eligibility for Video Recording

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June 14, 2018

June 14, 2018

PACER
17

CLERK'S NOTICE SETTING CASE MANAGEMENT CONFERENCE. Case Management Statement due by 7/16/2018. Initial Case Management Conference set for 7/25/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor. (Attachments: # 1 Standing Order, # 2 Standing Order for All Judges of the Northern District) (wsn, COURT STAFF) (Filed on 6/15/2018) (Entered: 06/15/2018)

1 Standing Order

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2 Standing Order for All Judges of the Northern District

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June 15, 2018

June 15, 2018

PACER
18

NOTICE OF MOTION AND MOTION to Dismiss for Lack of Jurisdiction filed by Jefferson B. Sessions, III, United States Department of Justice. Motion Hearing set for 7/26/2018 02:00 PM in San Francisco, Courtroom 09, 19th Floor before Judge Jon S. Tigar. Responses due by 7/2/2018. Replies due by 7/9/2018. (Attachments: # 1 Exhibit A- AG Memo, # 2 Exhibit B- Rescission Press Release, # 3 Exhibit C- Zendejas Letter, # 4 Exhibit D- Baudry Letter, # 5 Exhibit E- Prior Joint Statement)(Lopez-Morales, Cesar) (Filed on 6/18/2018) (Entered: 06/18/2018)

1 Exhibit A- AG Memo

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2 Exhibit B- Rescission Press Release

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3 Exhibit C- Zendejas Letter

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4 Exhibit D- Baudry Letter

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5 Exhibit E- Prior Joint Statement

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June 18, 2018

June 18, 2018

PACER
19

CLERK'S NOTICE Continuing Motion Hearing as to 18 MOTION to Dismiss for Lack of Jurisdiction. Due to a change in the Court's availability, the Motion Hearing set for 7/26/2018 is continued to 8/16/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor before Judge Jon S. Tigar. The briefing schedule is unchanged. (This is a text-only entry generated by the court. There is no document associated with this entry.) (wsn, COURT STAFF) (Filed on 6/19/2018) (Entered: 06/19/2018)

June 19, 2018

June 19, 2018

PACER
20

ADR Certification (ADR L.R. 3-5 b) of discussion of ADR options (Lopez-Morales, Cesar) (Filed on 6/27/2018) (Entered: 06/27/2018)

June 27, 2018

June 27, 2018

PACER
21

STIPULATION WITH PROPOSED ORDER filed by City and County of San Francisco. (Eisenberg, Sara) (Filed on 6/27/2018) (Entered: 06/27/2018)

June 27, 2018

June 27, 2018

PACER
22

NOTICE of need for ADR Phone Conference (ADR L.R. 3-5 d) (Eisenberg, Sara) (Filed on 6/27/2018) (Entered: 06/27/2018)

June 27, 2018

June 27, 2018

PACER
23

ADR Certification (ADR L.R. 3-5 b) of discussion of ADR options (Eisenberg, Sara) (Filed on 6/27/2018) (Entered: 06/27/2018)

June 27, 2018

June 27, 2018

PACER
24

ADR Clerk's Notice Setting ADR Phone Conference on July 19, 2018 at 10:00 AM Pacific time. Please note that you must be logged into an ECF account of counsel of record in order to view this document. (cmf, COURT STAFF) (Filed on 6/27/2018) (Entered: 06/27/2018)

June 27, 2018

June 27, 2018

PACER
25

STIPULATION AND ORDER re 21 STIPULATION AND [PROPOSED] ORDER filed by City and County of San Francisco. Signed by Judge Jon S. Tigar on June 28, 2018. (wsn, COURT STAFF) (Filed on 6/28/2018) (Entered: 06/28/2018)

June 28, 2018

June 28, 2018

RECAP
26

Stipulation and [Proposed] Order filed by City and County of San Francisco. (Eisenberg, Sara) (Filed on 7/9/2018) (Entered: 07/09/2018)

July 9, 2018

July 9, 2018

PACER
27

STIPULATION AND ORDER re 26 Stipulation and [Proposed] Order filed by City and County of San Francisco. Signed by Judge Jon S. Tigar on July 10, 2018. (wsn, COURT STAFF) (Filed on 7/10/2018) (Entered: 07/10/2018)

July 10, 2018

July 10, 2018

RECAP
28

CLERK'S NOTICE CONTINUING CASE MANAGEMENT CONFERENCE. The Initial Case Management Conference previously set for 7/25/2018 is continued to 12/19/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor. A Joint Case Management Statement is due 12/10/2018 by 5:00 PM. (This is a text-only entry generated by the court. There is no document associated with this entry.) (wsn, COURT STAFF) (Filed on 7/13/2018) (Entered: 07/13/2018)

July 13, 2018

July 13, 2018

PACER
29

ADR Remark: ADR Phone Conference held on 7/19/2018 by Howard Herman. A further ADR Phone Conference is scheduled for 9/18/2018, at 10:00 AM Pacific time. The call-in information remains the same. (af, COURT STAFF) (Filed on 7/20/2018) (This is a text-only entry generated by the court. There is no document associated with this entry.) (Entered: 07/20/2018)

July 20, 2018

July 20, 2018

PACER
30

First Amended Complaint for Declaratory and Injunctive Relief against Jefferson B. Sessions, III, United States Department of Justice. Filed by City and County of San Francisco. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J)(Herrera, Dennis) (Filed on 7/30/2018) (Entered: 07/30/2018)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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10 Exhibit J

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July 30, 2018

July 30, 2018

Clearinghouse
31

CLERK'S NOTICE TERMINATING MOTION AS MOOT re 18 MOTION to Dismiss for Lack of Jurisdiction. The Plaintiff has filed an 30 AMENDED COMPLAINT. The pending motion to dismiss is terminated as moot. (This is a text-only entry generated by the court. There is no document associated with this entry.) (wsn, COURT STAFF) (Filed on 8/1/2018) (Entered: 08/01/2018)

Aug. 1, 2018

Aug. 1, 2018

PACER
32

NOTICE filed by City and County of San Francisco of Notice of Disassociation of Counsel (Eisenberg, Sara) (Filed on 8/27/2018) (Entered: 08/27/2018)

Aug. 27, 2018

Aug. 27, 2018

PACER
33

ADR Remark: ADR Phone Conference held on 9/18/2018 by Howard Herman. (cmf, COURT STAFF) (Filed on 9/19/2018) (This is a text-only entry generated by the court. There is no document associated with this entry.) (Entered: 09/19/2018)

Sept. 19, 2018

Sept. 19, 2018

PACER
34

STIPULATION AND [PROPOSED] ORDER filed by Jefferson B. Sessions, III, United States Department of Justice. (Lopez-Morales, Cesar) (Filed on 9/20/2018) (Entered: 09/20/2018)

Sept. 20, 2018

Sept. 20, 2018

PACER
35

STIPULATION AND ORDER re 34 STIPULATION AND [PROPOSED] ORDER filed by United States Department of Justice, Jefferson B. Sessions, III. Responses due by 10/25/2018. Replies due by 11/13/2018. Motion Hearing set for 12/6/2018 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor before Judge Jon S. Tigar. Signed by Judge Jon S. Tigar on September 24, 2018. (wsn, COURT STAFF) (Filed on 9/24/2018) (Entered: 09/24/2018)

Sept. 24, 2018

Sept. 24, 2018

RECAP
36

MOTION to Dismiss for Lack of Jurisdiction filed by Jefferson B. Sessions, III, United States Department of Justice. Motion Hearing set for 12/6/2018 02:00 PM in San Francisco, Courtroom 09, 19th Floor before Judge Jon S. Tigar. Responses due by 10/25/2018. Replies due by 11/13/2018. (Attachments: # 1 Exhibit A- AG Memo, # 2 Exhibit B- July Press Release, # 3 Exhibit C- December Press Release, # 4 Exhibit D- Baudry Letter, # 5 Exhibit E- Refugee Employment Flyer, # 6 Exhibit F- New Joint Guidance on I-9 Audits, # 7 Exhibit G- New Employers' Flyer, # 8 Exhibit H- New Refugees' Flyer, # 9 Exhibit I- Prior Joint Statement, # 10 Exhibit J- New Joint Statement)(Lopez-Morales, Cesar) (Filed on 9/27/2018) (Entered: 09/27/2018)

1 Exhibit A- AG Memo

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2 Exhibit B- July Press Release

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3 Exhibit C- December Press Release

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4 Exhibit D- Baudry Letter

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5 Exhibit E- Refugee Employment Flyer

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6 Exhibit F- New Joint Guidance on I-9 Audits

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7 Exhibit G- New Employers' Flyer

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8 Exhibit H- New Refugees' Flyer

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9 Exhibit I- Prior Joint Statement

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10 Exhibit J- New Joint Statement

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Sept. 27, 2018

Sept. 27, 2018

PACER
37

NOTICE of Change of Address by Cesar A. Lopez-Morales (Lopez-Morales, Cesar) (Filed on 10/2/2018) (Entered: 10/02/2018)

Oct. 2, 2018

Oct. 2, 2018

PACER
38

OPPOSITION/RESPONSE to (re 36 MOTION to Dismiss for Lack of Jurisdiction) - Opposition to Defendants' Motion to Dismiss filed by City and County of San Francisco. (Walczak, Kenneth) (Filed on 10/25/2018) (Entered: 10/25/2018)

Oct. 25, 2018

Oct. 25, 2018

RECAP
39

REPLY (re 36 MOTION to Dismiss for Lack of Jurisdiction ) filed byJefferson B. Sessions, III, United States Department of Justice. (Lopez-Morales, Cesar) (Filed on 11/13/2018) (Entered: 11/13/2018)

Nov. 13, 2018

Nov. 13, 2018

PACER
40

Minute Entry for proceedings held before Judge Jon S. Tigar: Motion Hearing held on 12/6/2018 re 36 MOTION to Dismiss for Lack of Jurisdiction filed by United States Department of Justice, Jefferson B. Sessions, III. Case Management Statement due by 2/20/2019. Initial Case Management Conference set for 2/27/2019 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor. Total Time in Court: 52 minutes. Court Reporter: Jo Ann Bryce. (wsn, COURT STAFF) (Date Filed: 12/6/2018) (Entered: 12/06/2018)

Dec. 6, 2018

Dec. 6, 2018

PACER
41

TRANSCRIPT ORDER for proceedings held on 12/06/2018 before Judge Jon S. Tigar by City and County of San Francisco, for Court Reporter Jo Ann Bryce. (Walczak, Kenneth) (Filed on 12/6/2018) (Entered: 12/06/2018)

Dec. 6, 2018

Dec. 6, 2018

PACER
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ORDER GRANTING MOTION TO DISMISS by Judge Jon S. Tigar; granting 36 Motion to Dismiss for Lack of Jurisdiction. Amended Pleadings due by 1/9/2019. (wsn, COURT STAFF) (Filed on 12/10/2018) (Entered: 12/10/2018)

Dec. 10, 2018

Dec. 10, 2018

Clearinghouse
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Transcript of Proceedings held on 12/6/18, before Judge Jon S. Tigar. Court Reporter Jo Ann Bryce, telephone number 510-910-5888, joann_bryce@cand.uscourts.gov. Per General Order No. 59 and Judicial Conference policy, this transcript may be viewed only at the Clerk's Office public terminal or may be purchased through the Court Reporter until the deadline for the Release of Transcript Restriction after 90 days. After that date, it may be obtained through PACER. Any Notice of Intent to Request Redaction, if required, is due no later than 5 business days from date of this filing. (Re 41 Transcript Order ) Release of Transcript Restriction set for 4/4/2019. (Related documents(s) 41 ) (jabS, COURTSTAFF) (Filed on 1/4/2019) (Entered: 01/04/2019)

Jan. 4, 2019

Jan. 4, 2019

PACER
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ORDER DISMISSING CASE WITH PREJUDICE. Signed by Judge Jon S. Tigar on February 20, 2019. (wsn, COURT STAFF) (Filed on 2/20/2019) (Entered: 02/20/2019)

Feb. 20, 2019

Feb. 20, 2019

RECAP
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CLERK'S JUDGMENT. (wsn, COURT STAFF) (Filed on 2/20/2019) (Entered: 02/20/2019)

Feb. 20, 2019

Feb. 20, 2019

PACER

Case Details

State / Territory: California

Case Type(s):

Public Benefits/Government Services

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: April 5, 2018

Closing Date: May 20, 2019

Case Ongoing: No

Plaintiffs

Plaintiff Description:

City and County of San Francisco

Plaintiff Type(s):

City/County Plaintiff

Public Interest Lawyer: Yes

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

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Fines/Fees/Bail/Bond

Juveniles

Disability and Disability Rights:

disability, unspecified

Discrimination-basis:

Disability (inc. reasonable accommodations)

Immigration status