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Keywords

lawsuitplaintiffinjunctionappealcomplianceimmigration law
plaintiffstatuteinjunctionmotionregulationimmigration law

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El Cenizo, City of, v. Texas

Facts

In May 2017, the Texas Legislature enacted Senate Bill 4 (SB4) to prohibit sanctuary city policies, imposing duties on local officials to cooperate with federal immigration enforcement. The law includes provisions that prevent local entities from limiting immigration enforcement and mandates compliance with ICE detainer requests. Several Texas cities and local officials filed a lawsuit challenging SB4, claiming it violated constitutional rights and was preempted by federal law. The district court issued a preliminary injunction against several provisions of SB4, leading to the appeal.

Before SB4 could go into effect, several Texas cities, counties, local law-enforcement and city officials, and advocacy groups challenged the law in three consolidated actions. The plaintiffs sought a preliminary injunction, and the district court found the plaintiffs likely to prevail on the following claims: ?? Section 752.053(b)(3)'s assistance-cooperation provision is field and conflict preempted by federal immigration law; ?? Section 752.053(a)(1)'s 'endorse' prohibition violates the First and Fourteenth Amendments because it is overbroad, discriminates on the basis of viewpoint, and is unconstitutionally vague; ?? Section 752.053(a)(1) and (a)(2)'s 'materially limits' prohibitions are unconstitutionally vague under the Fourteenth Amendment; and ?? Article 2.251's ICE-detainer mandate violates the Fourth Amendment.

Issue

The main legal issues include whether SB4 is preempted by federal immigration law, whether its provisions violate the First, Fourth, and Fourteenth Amendments, and whether the plaintiffs have standing to challenge the ICE detainer mandate.

The plaintiffs alleged a battery of constitutional violations: (I) SB4 is preempted by federal immigration law, (II) SB4's 'endorse' prohibition violates the First and Fourteenth Amendments, (III) SB4's ICE-detainer mandate violates the Fourth Amendment, and (IV) SB4's phrase 'materially limits' is unconstitutionally vague under the Fourteenth Amendment.

Rule

The court applied principles of preemption, determining that state laws can be preempted by federal laws if Congress has occupied the field or if there is a conflict between state and federal law. The court also evaluated constitutional standards regarding vagueness and the rights of local officials.

The court found that the plaintiffs have not satisfied this standard. Congress has not preempted the field that SB4 regulates.

Analysis

The court found that the plaintiffs did not meet the burden of proving that SB4 was field preempted by federal law. It ruled that Congress had not preempted the field that SB4 regulates and that there was no conflict between SB4's provisions and federal law. The court also addressed the constitutional challenges, concluding that the provisions of SB4 did not violate the First or Fourth Amendments, and that the phrase 'materially limits' was not unconstitutionally vague.

The district court found only one provision of SB4 field preempted. According to the district court, Section 752.053(b)(3)'s assistance-cooperation provision impermissibly regulates the field of 'immigration enforcement,' which Congress fully preempted through comprehensive regulation.

Conclusion

The Fifth Circuit affirmed in part and vacated in part the district court's injunction, ruling that most provisions of SB4 were constitutional and not preempted by federal law, except for the application of the 'endorse' prohibition to elected officials.

With one exception, SB4's provisions do not, on their face, violate the Constitution. For the following reasons, we uphold the statute in its entirety except for the application of the 'endorsement' prohibition, Tex. Gov't Code 752.053(a)(1), to elected officials.

Who won?

The State of Texas prevailed in the case, as the court upheld the majority of SB4's provisions, finding that they did not conflict with federal law and were constitutional.

The stay panel granted the motion in part, finding Texas likely to prevail on the Fourth Amendment and preemption claims, and stayed the injunction as to article 2.251's ICE-detainer mandate and Section 752.053(b)(3)'s assistance-cooperation provision.

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