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Keywords

lawsuitplaintiffstatuteinjunctionappealcommon law
lawsuitplaintiffstatuteinjunctionappealcommon law

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Ryan v. Immigration and Customs Enforcement

Facts

ICE has been conducting civil enforcement actions to arrest removable noncitizens in courthouses, which led to concerns from various state officials and organizations about the impact on the judicial system and access to justice for immigrant communities. In response, the plaintiffs filed a lawsuit challenging ICE's Directive that formalized its policy on courthouse arrests, arguing that it exceeded ICE's statutory authority under the Immigration and Nationality Act (INA). The district court initially granted a preliminary injunction against ICE's actions, leading to the appeal.

ICE has been conducting civil enforcement actions to arrest removable noncitizens in courthouses, which led to concerns from various state officials and organizations about the impact on the judicial system and access to justice for immigrant communities. In response, the plaintiffs filed a lawsuit challenging ICE's Directive that formalized its policy on courthouse arrests, arguing that it exceeded ICE's statutory authority under the Immigration and Nationality Act (INA). The district court initially granted a preliminary injunction against ICE's actions, leading to the appeal.

Issue

Did the district court err in granting a preliminary injunction against ICE's arrests of noncitizens in courthouses based on the plaintiffs' claims regarding the INA and common law privileges?

Did the district court err in granting a preliminary injunction against ICE's arrests of noncitizens in courthouses based on the plaintiffs' claims regarding the INA and common law privileges?

Rule

The court applied the principle that the power of an executive agency is prescribed by Congress, and actions taken outside that authority are ultra vires and violate the Administrative Procedure Act (APA). The court also considered the nonderogation canon of statutory construction, which presumes that statutes do not alter long-established common law principles unless explicitly stated.

The plaintiffs' argument presents a pure question of law, which we review de novo. See Corp. Techs., 731 F.3d at 10. It is a bedrock principle that the power of an executive agency administering a federal statute 'is 'authoritatively prescribed by Congress.'" City of Providence, 954 F.3d at 31 (quoting City of Arlington v. FCC, 569 U.S. 290, 297, 133 S. Ct. 1863, 185 L. Ed. 2d 941 (2013)). When an agency acts in a manner not authorized by statute, its action is ultra vires and a violation of the APA. See id.; see also 5 U.S.C. 706(2)(C).

Analysis

The court found that the INA does not explicitly prohibit ICE from conducting civil arrests in courthouses. The plaintiffs' argument relied on the nonderogation canon, suggesting that a common law privilege against civil courthouse arrests should be presumed to be incorporated into the INA. However, the court determined that the text of the INA grants broad authority to ICE for civil arrests, and there was no clear indication from Congress that such arrests were to be restricted in courthouses.

The court found that the INA does not explicitly prohibit ICE from conducting civil arrests in courthouses. The plaintiffs' argument relied on the nonderogation canon, suggesting that a common law privilege against civil courthouse arrests should be presumed to be incorporated into the INA. However, the court determined that the text of the INA grants broad authority to ICE for civil arrests, and there was no clear indication from Congress that such arrests were to be restricted in courthouses.

Conclusion

The court vacated the district court's preliminary injunction, concluding that the plaintiffs were unlikely to succeed on the merits of their claims regarding ICE's authority to conduct civil arrests in courthouses.

The court vacated the district court's preliminary injunction, concluding that the plaintiffs were unlikely to succeed on the merits of their claims regarding ICE's authority to conduct civil arrests in courthouses.

Who won?

The United States Immigration and Customs Enforcement (ICE) prevailed in the case because the court found that the plaintiffs were unlikely to succeed on their claims against ICE's authority to conduct civil arrests in courthouses.

The United States Immigration and Customs Enforcement (ICE) prevailed in the case because the court found that the plaintiffs were unlikely to succeed on their claims against ICE's authority to conduct civil arrests in courthouses.

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