Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Gates

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Part 2 of 3

E. Conditions at B-18 and the Denial of Access to Counsel

72. James Pendergraph, former Executive Director of ICE Office of State and Local Coordination once said, “If you don’t have enough evidence to charge someone criminally but you think he’s illegal, we can make him disappear.”62 That ethos is animating Defendants’ Los Angeles operations today.

73. Individuals detained in immigration operations have a right to counsel that is rooted in the Due Process Clause of the Fifth Amendment. Usubakunov v. Garland, 16 F.4th 1299, 1304 (9th Cir. 2021); Biwot v. Gonzales, 403 F.3d 1094, 1098 (9th Cir. 2005); see also Torres v. United States Dep’t of Homeland Sec., 411 F. Supp. 3d 1036, 1060-61 (C.D. Cal. 2019). When the government detains individuals as part of immigration enforcement efforts, it cannot impose restrictions on access to attorneys that undermine the opportunity to obtain counsel or communicate with retained counsel. See Orantes-Hernandez v. Thornburgh, 919 F.2d 549, 554, 565 (9th Cir. 1990); see also Usubakunov, 16 F.4th at 1300 (“Navigating the asylum system with an attorney is hard enough; navigating it without an attorney is a Herculean task.”); Comm. of Cent. Am. Refugees v. INS, 795 F.2d 1434, 1439 (9th Cir. 1986) (recognizing that impediments to communication, especially in connection with a difficult-to-access facility, can constitute a “constitutional deprivation” where they obstruct an “established on-going attorney-client relationship.”).

74. Further, civil detainees have “a right to adequate food, shelter, clothing, and medical care.” Youngberg v. Romeo, 457 U.S. 307 (1982). Their conditions of confinement become unconstitutional if they “amount to punishment,” Bell v. Wolfish, 441 U.S. 520, 535 (1979), in other words, when “the harm or disability caused by the government’s action . . . significantly exceed[s], or [is] independent of, the inherent discomforts of confinement[.]” Demery v. Arpaio, 378 F.3d 1020, 1030 (9th Cir. 2004). During the ongoing raids, and as an integral part of the policy and pattern of unlawful stops and arrests described above, Defendants have been taking individuals who are swept up en masse to the basement of the federal building at 300 North Los Angeles Street in Los Angeles, commonly referred to as “B-18.” B-18 is a facility for immigrant detainees designed to hold a limited number of individuals temporarily so they can be processed and released, or processed and transported to a long-term detention facility. It does not have beds, showers, or medical facilities.

75. B-18 was previously the subject of litigation in this District, and a lawsuit over the inhumane treatment of detainees there resulted in a 2009 settlement agreement requiring that individuals not be held at B-18 for more than 12 hours. See Castellano v. Napolitano, No. 2:09-CV-02281 (C.D. Cal. Sept. 16, 2009). Other provisions of the agreement required that detainees at B-18 be allowed to “visit with current or prospective legal representatives and their legal assistants seven days a week, including holidays, for eight hours per day on regular business days (Monday through Friday), and four hours per day on weekends and holidays.”

76. The settlement agreement has since expired. But under the immense pressure to receive individuals arrested in recent weeks, the unlawful conditions that led to the settlement more than a decade ago are recurring today. Individuals taken to B-18 are being kept in overcrowded, inhumane conditions. They are held in small windowless rooms with dozens or more other detainees, in extremely cramped quarters. Some rooms are so cramped that detainees cannot sit, let alone lie down, for hours at a time.

77. As of June 20, 2025, upon information and belief, over 300 individuals were being held at B-18. They are expected to sleep in cold rooms on floors without cots, bedding, or blankets. Some are even forced to sleep in tents outside.

78. When asked why detainees have been forced to sleep in such cramped conditions, an officer at B-18 explained that B-18 is meant to be a processing center, not a detention facility. Historically, processing of individuals in removal proceedings would result in the release of an individual detained pending their next court hearing or, barring release, immediate transfer to a detention facility. But B-18 is not being used that way today, and individuals are being held there far longer than 12 hours, often for days on end.

79. Detainees are also routinely deprived of food. Some have not even been given water other than what comes out of the combined sink and toilet in the group detention room. And upon asking for food, detainees have been told repeatedly that the facility has run out.

80. Detainees are routinely denied access to necessary medical care and medications, too. Individuals with conditions that require consistent medications and treatment are not given any medical attention, even when that information is brought to the attention of the officers on duty. The facility cannot even provide detainees with basic hygiene. Individuals who are menstruating have had to wait long periods before receiving menstrual pads, if they receive them at all.

81. To make matters worse—and, indeed, to keep the true nature and scope of Defendants’ constitutional violations, including those related to stops and arrest, hidden from the outside world—individuals detained at B-18 have had their access to prospective or retained counsel severely and unconstitutionally restricted.

82. On June 6, 2025, attorneys and legal representatives from organizational Plaintiffs CHIRLA and ImmDef attempted to gain access to B-18 to advise detainees of their rights and assess their eligibility for relief, but they were not permitted to enter.

83. When they returned to B-18 the next morning, attorneys identified a handwritten notice on the door of the family and attorney entrance at B-18 indicating that they would not permit any visits that day. Federal officers then deployed an unknown chemical agent against family members, attorneys, and representatives, including CHIRLA and ImmDef legal staff, who were peacefully requesting access to detained individuals. The chemical agent that federal agents sprayed caused everyone to cough and inflicted a burning sensation in the eyes, nose, and throat.

84. That same morning, numerous unmarked white vans quickly departed B-18 with a group of detainees. CHIRLA and ImmDef attorneys and representatives attempted to loudly share know your rights information with the detainees in the vans. To prevent the detainees from hearing their rights, and therefore exercising them, the federal agents blasted their horns to drown them out.

85. On June 7, 2025, another ImmDef attorney arrived at B-18 to find a handwritten notice that the facility was closed to visitation, as shown below:63

[x]

[x]

86. As a result, attorneys and family members were unable to access B-18 the entire weekend during the first few days of the raids.

87. On the rare occasions when attorneys and family members have been allowed access to their clients or loved ones, they have been made to wait hours at a time to see them, and the resulting visits have been limited to a mere five to 10 minutes. Detention officers screen the very limited phone calls that detainees are permitted to make, and phone calls cannot be used for confidential legal communications.

88. In many cases, attorneys and family members have been unable to determine whether a particular individual is even detained at B-18, or whether they have been transferred to another facility. B-18 officers have refused to provide clear answers to questions about detainees’ whereabouts, or refused to answer questions altogether. ICE’s online locator, which provides information about detainees’ location, is not updated in a timely manner.

89. The severe access restrictions have persisted as Defendants’ mass arrests continue to occur across Southern California.

90. On June 16, 2025, ImmDef attorneys, as well as Congressman Jimmy Gomez, arrived at B-18 around 3:00 p.m. on a day when B-18 was purportedly open for visiting between 8:00 a.m. to 4:00 p.m. But they were denied access, along with family members who had been instructed to go to B-18 to pick up their loved ones’ possessions.

91. On June 19, 2025, an ImmDef attorney arrived at B-18 to meet with detainees, including one who was scheduled for a chemotherapy appointment the next day. Despite showing a doctor’s note confirming the appointment and specifying that missing the appointment would be detrimental to the detainee’s health, the guards repeatedly would not allow the attorney to meet with the ill detainee. One officer told the attorney that he had no way to find the individual because hundreds of people were detained in the facility.

92. B-18 officers have and continue to consistently close the doors to detainees’ prospective or retained counsel at unexpected and unexplained times.

93. The use of B-18 as a makeshift, long-term detention center for hundreds of individuals has and continues to cause significant, ongoing harm. Defendants have intentionally restricted detainees’ access to those who may be able to intervene on their behalf at a critical time when they are likely to face imminent government action in their case. Indeed, one of ImmDef’s clients who has been granted asylum and who should never have been arrested was picked up at a Home Depot looking for work. He would have disappeared into the detention system if not for an ImmDef attorney’s last minute intervention at B-18 on June 19, 2025.

94. In fact, some individuals have accepted voluntary departure from this country under 8 U.S.C. § 1229c(a)(1), without having had the opportunity to consult with counsel, even though due process requires that any waiver of a right to a hearing be knowing and voluntary. See, e.g., United States v. Ramos, 623 F.3d 672, 682–83 (9th Cir. 2010). Upon information and belief, the inhumane conditions at B-18 create a coercive environment that pressures some of those detained individuals to take voluntary departure without first consulting with counsel and despite potential deportation relief because they fear lengthy detention in deplorable conditions.

95. Combined with the continued deplorable conditions at B-18—lack of food, medical care, basic hygiene, and overcrowding—B-18 is a disaster continuing to happen. And until these issues are resolved, the true scale of the legal violations Defendants are engaged in will remain unknown.

F. Defendants’ Pattern of Illegal Conduct Is Officially-Sanctioned

96. Defendants’ unlawful stops, arrests, denial of access to counsel and conditions at B-18 are the predictable result of directives from top officials to agents and officers.

97. In January, the administration gave ICE field offices an arrest quota of 75 arrests a day.64 As offices attempted to carry out such a mandate, workplace raids increased,65 ICE check-ins became traps,66 and courthouse arrests surged.67

98. Also, to help meet the quota, the administration granted agencies outside of DHS immigration enforcement powers.68

99. Meanwhile, the administration began systematically dismantling internal accountability mechanisms and restraints on immigration agents’ and officers’ conduct. The administration shut down multiple oversight agencies (retaining only a version of their former selves after the administration was sued).69 Investigations were closed.70 Officers no longer had to abide by enforcement priorities.71 Long-standing guidance restricting enforcement operations in sensitive locations—schools, hospitals, places of worship and public demonstrations—was rescinded.72

100. But these changes were not enough, according to the administration. In late May, Deputy Chief of Staff Stephen Miller summoned 25 ERO Field Office Directors and 25 HSI Special Agents to a meeting to demand that “everybody” be targeted.73 Under Miller’s directive, agents no longer needed to develop vetted target lists of individuals suspected of being in the United States unlawfully.74 ICE agents were instructed in an email to “turn the creativity knob up to 11” and aggressively “push the envelope,” including by pursuing “collaterals”—individuals that by definition would not have warrants.75 As another e-mail put it: “If it involves handcuffs on wrists, it’s probably worth pursuing.”76

101. The administration set a new arrest quota of 3,000 arrests per day and reportedly threatened job consequences if officials failed to meet arrest quotas.77

102. The overriding message to agents and officers carrying out immigration operations on the ground was to prioritize arrest numbers, regardless of the law. Agents and officers were granted sweeping discretion to achieve this goal.

G. Defendant Agencies Have a History of Unconstitutional and Unlawful Conduct

103. The agencies involved in the Los Angeles area immigration raids include DHS and its components, ICE ERO, ICE HSI, and the U.S. Border Patrol, as well as DOJ law enforcement agencies including the FBI78 and others (including ATF79 and DEA).80 A number of these agencies have a history of engaging in unconstitutional and unlawful stops and arrests.

104. For example, the U.S. Border Patrol has a documented history of Fourth Amendment violations in the U.S. interior: U.S. Border Patrol agents have relied on perceived race or ethnicity to select who to stop, conducted suspicionless stops, executed warrantless home raids, and carried out illegal worksite operations. Courts have repeatedly intervened to curb these practices. See LaDuke v. Nelson, 762 F.2d 1318 (9th Cir. 1985), amended, 796 F.2d 309 (9th Cir. 1986), affirmed, 799 F.2d 547, 551 (9th Cir. 1986) (upholding permanent classwide injunction against warrantless raids on farmworker housing in Washington, Idaho, and Montana); International Molders’ and Allied Workers’ Local Union No. 164 v. Nelson, 643 F. Supp. 884, 887-89, 899-901 (N.D. Cal. 1986) (granting preliminary injunction barring the now-defunct Livermore Border Patrol Sector from replicating the unlawful practices it had used in “Operation Jobs,” a weeklong series of about 50 workplace raids across Northern California where agents stopped workers for questioning without reasonable suspicion and arrested people who refused to answer questions, including U.S. citizens).

105. Most recently, the El Centro Sector of the U.S. Border Patrol, one of the key participants in the raids being challenged in this suit, was the focus of a suit filed in the Eastern District of California over a Kern County operation called “Operation Return to Sender.” The tactics challenged here—including widespread racial profiling, suspicionless stops, and warrantless arrests without determination of flight risk—bear the unmistakable hallmarks of “Operation Return to Sender.”81 Like the raids challenged here, “Operation Return to Sender” spread through agricultural communities and also targeted day laborer pick up sites. On April 29, 2025, the court granted a preliminary injunction barring the U.S. Border Patrol from engaging in these unlawful practices. United Farm Workers v. Noem, No. 1:25-CV-00246 JLT CDB, 2025 WL 1235525, at *1 (E.D. Cal. Apr. 29, 2025). The ruling recognizes that, in the Ninth Circuit, “Hispanic appearance is of little or no use in determining which particular individuals among the vast Hispanic populace should be stopped.” Id. at *46 (quoting United States v. Montero-Camargo, 208 F.3d 1122, 1134 (9th Cir. 2000)). And the El Centro Sector Chief Bovino, who led “Operation Return to Sender,” is now at the helm of operations in the Los Angeles area, inviting him to replicate his tactics in this District.

106. ICE, which typically handles immigration enforcement in the interior and “manag[es] all aspects of the immigration enforcement process, including the identification, arrest, detention, and removal of [noncitizens],”82 has likewise been found to violate the Fourth Amendment, statutory, and regulatory rights of individuals it encounters in the field.

107. For instance, in 2008, ICE HSI agents conducted a workplace raid in Van Nuys, California. Agents executed a search warrant but also engaged in detentive stops of workers without individualized reasonable suspicion. The Ninth Circuit eventually ruled that this was unlawful and invalidated the ensuing removal proceedings. Perez Cruz v. Barr, 926 F.3d 1128, 1137 (9th Cir. 2019) (citing 8 C.F.R. § 287.8(b)).

108. In Nava v. DHS, a plaintiff class in Chicago challenged a pattern and practice of ICE conducting warrantless arrests without making required determinations under 8 U.S.C. § 1357. Nava v. Dep’t of Homeland Sec., 435 F. Supp. 3d 880, 885 (N.D. Ill. 2020). The case resulted in a settlement that included a nationwide policy about warrantless arrests and vehicle stops.83 In June 2025, despite a pending motion to enforce the settlement agreement and motion to extend the settlement agreement, ICE terminated its policy under the settlement that required officers to document the circumstances of warrantless arrests and vehicle stops.84

109. Meanwhile, in this District, in May 2024, plaintiffs secured a summary judgment order in Kidd v. Mayorkas, 734 F. Supp. 3d 967, 982 (C.D. Cal. 2024), holding unlawful ICE’s practice of entering onto the curtilage of homes during “knock and talks” for the purpose of carrying out arrests without a judicial warrant. Public reports confirm that in late May, Defendant Essayli, instead directed DOJ law enforcement agencies to take over door knocking tasks.85

110. In sum, Defendants in this case have demonstrated a willingness to bypass basic constitutional, statutory, and regulatory requirements when it comes to immigration enforcement, even before top-down pressure demanded adherence with dramatically higher arrest quotas. When their practices have come under scrutiny, rather than take the opportunity to conform their conduct to the law, they have evaded accountability by replicating those practices in another geographic area, declining to document what they do, and directing other federal partners not under court order to take over tasks that have been found to be unconstitutional. It is therefore no surprise that the immigration raids in the Los Angeles area have been marked by systematic disregard of the law.

H. Experiences of Individual Plaintiffs

Petitioner-Plaintiff Pedro Vasquez Perdomo


111. In the early morning of June 18, 2025, in Pasadena, California, Petitioner-Plaintiff Vasquez Perdomo was waiting at a bus stop across the street from Winchell’s Donuts with several co-workers to be picked up for a job.

112. Suddenly, about four cars converged on his location, and about half a dozen masked agents jumped out on either side of him. They had weapons and masks, and did not identify themselves.

113. To Petitioner-Plaintiff Vasquez Perdomo, it felt like a kidnapping. He tried to leave but was swiftly surrounded, grabbed, handcuffed, and put into one of the vehicles.

114. At the time he was handcuffed, agents did not have reasonable suspicion of a violation of immigration law.

115. It was only after he was brought to a nearby CVS parking lot that agents checked Petitioner-Plaintiff Vasquez Perdomo’s identification.

116. No warrant was shown. Upon information and belief, agents did not have a warrant of any kind for Petitioner-Plaintiff Vasquez Perdomo’s arrest.

117. Agents proceeded with a warrantless arrest of Petitioner-Plaintiff Vasquez Perdomo without making an individualized determination of risk of flight.

118. If agents had evaluated Petitioner-Plaintiff Vasquez Perdomo for risk of flight, they would have learned he had lived in Pasadena for decades.


119. Agents did not inform Petitioner-Plaintiff Vasquez Perdomo that they were immigration officers authorized to make an arrest or of the basis for his arrest.

120. At the time this action was filed, Petitioner-Plaintiff Vasquez Perdomo had been transported to and was being held at the federal building at 300 North Los Angeles St. in B-18. There he experienced extremely crowded and unsanitary conditions, was given little to eat or drink, and slept on the floor. Today he remains in custody at the Adelanto ICE Processing Center.

121. Petitioner-Plaintiff has representation in his removal proceedings. His counsel is located in Pasadena, California.

122. Petitioner-Plaintiff’s family is located in Pasadena, California.

123. Petitioner-Plaintiff is diabetic and has felt increasingly ill since his arrest. He has felt depressed since his arrest and reasonably fears being racially profiled again if he is released from detention.

Petitioner-Plaintiff Carlos Alexander Osorto

124. In the early morning of June 18, 2025, in Pasadena, California, Petitioner-Plaintiff Osorto was waiting to be picked up for work with his co-worker Petitioner-Plaintiff Vasquez Perdomo.

125. When federal agents approached, Petitioner-Plaintiff Osorto was terrified. He had seen videos of what had been happening around Los Angeles and also had heard of masked people who were not even government agents taking community members away. He tried to run, but one of the agents caught up to him and pointed a taser at his head and said “stop or I’ll use it!” Petitioner-Plaintiff Osorto stopped immediately.

126. Petitioner-Plaintiff Osorto was handcuffed and put into a vehicle.

127. At the time he was handcuffed, agents did not have reasonable suspicion of a violation of immigration law.

128. It was only after he was brought to a nearby CVS parking lot that agents asked Petitioner-Plaintiff Osorto if he had papers.

129. No warrant was shown. Upon information and belief, agents did not have a warrant of any kind for Petitioner-Plaintiff Osorto’s arrest.

130. Agents proceeded with a warrantless arrest of Petitioner-Plaintiff Osorto without making an individualized determination of risk of flight.

131. If agents had evaluated Petitioner-Plaintiff Osorto for risk of flight, they would have learned he had built homes all around Los Angeles, lived in Pasadena for more than a decade, and had 7 grandchildren who are U.S. citizens.

132. Agents did not inform Petitioner-Plaintiff Osorto that they were immigration officers authorized to make an arrest or of the basis for his arrest.

133. At the time this action was filed, Petitioner-Plaintiff Osorto had been transported to and was being held at the federal building at 300 North Los Angeles St. in B-18. The facility was full and when people asked for help officers told them there was no food, no water, and no medicine. Today he remains in custody at the Adelanto ICE Processing Center.

134. Petitioner-Plaintiff Osorto has representation in his removal proceedings. His counsel is located in Pasadena, California.

135. Petitioner-Plaintiff Osorto’s family is located throughout Los Angeles County, including in Pasadena, California.

136. Petitioner-Plaintiff Osorto has developed high blood pressure, he believes as a result of the stress he has experienced. He has been scared and overwhelmed by what happened and fears being targeted again, if he is released, for being a Latino person in construction clothes.
Petitioner-Plaintiff Isaac Antonio Villegas Molina

137. In the early morning of June 18, 2025, in Pasadena, California, Petitioner-Plaintiff Villegas Molina was waiting to be picked up for work with his co-workers Petitioner-Plaintiff Vasquez Perdomo and Petitioner-Plaintiff Alexander Osorto.

138. When federal agents approached, Petitioner-Plaintiff Villegas Molina was also afraid but tried his best to stay calm.

139. An agent yelled at Petitioner-Plaintiff Villegas Molina not to run, even though he was still and calm. He was told to provide his ID and he provided his California ID, but the agent kept questioning him. At this point, he did not feel free to leave.

140. When they were questioning him, agents did not have reasonable suspicion of a violation of immigration law.

141. No warrant was shown. Upon information and belief, agents did not have a warrant of any kind for Petitioner-Plaintiff Villegas Molina’s arrest.

142. Agents proceeded with a warrantless arrest of Petitioner-Plaintiff Villegas Molina without making an individualized determination of risk of flight.

143. If agents had evaluated Petitioner-Plaintiff Villegas Molina for risk of flight, they would have learned he had lived in Pasadena for 13 years and had worked at restaurants across Los Angeles.

144. Agents did not inform Petitioner-Plaintiff Villegas Molina that they were immigration officers authorized to make an arrest or of the basis for his arrest.

145. At the time this action was filed, Petitioner-Plaintiff Villegas Molina had been transported to and was being held at the federal building at 300 North Los Angeles St. in B-18. He slept on the floor and was given almost nothing to eat. Today he remains in custody at the Adelanto ICE Processing Center.

146. Petitioner-Plaintiff has representation in his removal proceedings. His counsel is located in Pasadena, California.

147. Petitioner-Plaintiff has had a difficult time in detention. He fears being targeted again because of his race.

Plaintiff Jorge Hernandez Viramontes

148. On the morning of June 18, 2025, Plaintiff Hernandez Viramontes was working at a car wash in Orange County, where he has worked for approximately 10 years, when immigration agents arrived. This was the third time that agents had raided the carwash since June 9, 2025. 149. During this visit by agents, like with previous visits, agents did not identify themselves. They did not show a warrant. They simply went from person to person interrogating them about their identity and immigration status.

150. Agents questioned Plaintiff Hernandez Viramontes’ co-worker, a U.S. citizen, about his citizenship three separate times in one visit.

151. When agents got to Plaintiff Hernandez Viramontes, they asked him if he was a citizen, and he replied yes and explained he was a dual citizen of the U.S. and Mexico. They asked for an ID, which he provided. Agents then explained that his ID wasn’t enough and since he didn’t have his passport, they were taking him.

152. Agents placed Plaintiff Hernandez Viramontes in a vehicle and transported him away. During this time, Plaintiff Hernandez Viramontes did not know if they were going to take him to a detention center.

153. Agents verified his citizenship and about 20 minutes later, brought him back to the car wash, but not before his brother called his wife, who had become deeply worried.

154. When agents brought Plaintiff Hernandez Viramontes back to the car wash, they did not apologize.

155. Shortly after agents returned Plaintiff Hernandez Viramontes to the car wash, yet another group of agents raided the carwash again.

156. Plaintiff Hernandez Viramontes is shaken by what happened and fears being targeted again on the basis of his Latino appearance and accent.


Plaintiff Jason Brian Gavidia

157. In the afternoon of June 12, 2025, Plaintiff Gavidia, a U.S. citizen, was at a tow yard in Los Angeles County that was visited by immigration agents conducting a roving patrol.86

158. Around 4:30 p.m., upon hearing someone say immigration agents may be at the premises, Plaintiff Gavidia went outside to confirm this. At the time, his clothes were dirty from working on his car.

159. On the sidewalk outside the gate, Plaintiff Gavidia saw a federal agent between two cars step forward. Soon after, Plaintiff Gavidia saw several other agents wearing similar vests with the words “Border Patrol Federal Agent.” He also noticed the agents were carrying handguns and at least two of the agents had a military-style rifle.

160. As Plaintiff Gavidia attempted to head back inside the tow yard premises, an agent said, “Stop right there.” At this point, Plaintiff Gavidia did not feel that he could leave. The agent was masked.

161. While the agent approached Plaintiff Gavidia, another unmasked agent ran towards him and asked if he was American. Plaintiff Gavidia told the agent that he is American multiple times. The agent responded by asking, “What hospital were you born in?” Plaintiff Gavidia calmly replied that he did not know. The agent repeated the same question two more times, and each time Plaintiff Gavidia provided the same answer. At that point, the agents forcefully pushed Plaintiff Gavidia up against the metal gated fence, put his hands behind his back, and twisted his arm. Plaintiff Gavidia had been on his phone, and the masked agent also took his phone from his hand at that point.

162. Plaintiff Gavidia explained that the agents were hurting him and that he was American. The unmasked agent asked a final time, “What hospital were you born in?” Plaintiff Gavidia responded again that he did not know and said East L.A. Plaintiff Gavidia then told the agents that he could show them his Real ID. The agents had not asked to see Plaintiff Gavidia’s identification.

163. When Plaintiff Gavidia showed his Real ID to the agents, one of them took it from him. It ultimately took about 20 minutes for -Plaintiff Gavidia to get his phone back. But the agents never returned Plaintiff Gavidia’s Real ID.

164. Plaintiff Gavidia’s interaction with the federal agents was one of the worst experiences he has ever had. He is disturbed and deeply concerned about being targeted again because of his race.

I. Harms to Organizational Plaintiffs and/or Their Members

165. Since they began on June 6, 2025, federal immigration raids have led to the arrest of over 1,500 people and counting, many of whom have been stopped without reasonable suspicion, and/or arrested without probable cause. For those who have been arrested, many have been denied the right to consult with their attorneys, and have been held under conditions with insufficient food, shelter, clothing, and medical care. These conditions, of both arrests and detentions, have caused profound harm to individuals and families, and destabilized entire communities. The chilling effect extends beyond directly impacted individuals. For example, the Mayor of Pasadena described seeing a “huge drop in attendance at local community programs,” once “vibrant neighborhoods” now “eerily quiet” and business owners “concerned that their workers and customers alike are too afraid to show up.”87

166. These harms have extended to organizational Plaintiffs and/or their members.

Plaintiff Los Angeles Worker Center Network (LAWCN)

167. LAWCN is a regional organization made up of eight worker centers and labor organizations that work together to build power and develop worker leadership organizing with Black, immigrant, and refugee workers and other workers of color in the Los Angeles region. LAWCN’s member organizations work to improve conditions in low-wage industries, including car wash, garment, home care, restaurant, retail, warehouse, and other low-wage sectors. LAWCN’s members each have at least one representative on its Executive Committee, and the Committee has regular standing meetings in which the member organizations provide input on LAWCN’s strategic planning and goals, including by having the voting members cast votes on key strategic questions.

168. LAWCN improves conditions for low-wage workers through capacity building, organizing, services, and policy advocacy at the city, county, and state level. In pursuing LAWCN’s mission to build the power and grow the capacity of local worker centers to organize and advocate for low-wage workers, LAWCN has a long term and sustained focus on issues related to immigration and immigrant workers. LAWCN has engaged in policy reform and advocacy aimed at increasing immigrant workers’ access to governmental services. Additionally, through its capacity-building efforts, LAWCN’s work supports immigrant justice by improving the conditions and dignity of immigrant workers in Southern California.

169. LAWCN brings this suit on behalf of its member organizations, worker centers that organize and advocate for low-wage workers in the greater Los Angeles region. At least one of LAWCN’s member organizations, CLEAN Carwash Worker Center (CLEAN), has been harmed by the ongoing raids in Southern California. CLEAN is a grassroots worker center that fights for the self-determination of immigrant and working-class people by empowering carwash workers to make lasting changes in the carwash industry and their communities.

170. CLEAN has approximately 1,800 members who are carwash workers from the greater Los Angeles area. Its members are predominantly Latino and many are immigrants or the children of immigrants. CLEAN has three tiers of membership available to workers, depending on how much each member wishes to participate in CLEAN’s organizing work. CLEAN’s members help set the priorities for the organization. It holds standing membership meetings during which members provide feedback and input into CLEAN’s goals and work.

171. CLEAN’s mission includes fighting for the self-determination of immigrants. A consistent focus of CLEAN’s work is to provide its members access to immigration-related support and resources. Some of this work involves providing training and support to members about immigration issues. CLEAN has also organized programming and events, including attending rallies and events, in support of immigration reform.

172. Carwashes have been a consistent and ongoing target of immigration agents during the course of the raids—at least two dozen have been raided so far.88 Some carwashes have closed because so many workers have either been detained or fear future raids.89

173. Dozens of CLEAN’s members have been detained by immigration agents while at work. At least one identifiable CLEAN member, Jesus Aristeo Cruz Utiz, has been subjected to Defendants’ unlawful stop and arrest practices.

174. Many CLEAN members, regardless of the stability or permanence of their immigration status, fear that immigration agents will subject them to unlawful stops and arrests. They are terrified that masked and unidentifiable immigration agents will invade their workplaces without a warrant, grab them, handcuff them, and take them away. They are fearful of being racially profiled and stopped by immigration agents while in public or at their places of employment.

Plaintiff United Farm Workers (UFW)



175. Founded in 1962 by Cesar Chavez, Dolores Huerta, Larry Itliong and other labor leaders, UFW is the largest farm worker union in the country. UFW’s mission is to improve the lives, wages, and working conditions of agricultural workers and their families. UFW is dedicated to the cause of eliminating discrimination against farm workers, immigrants, people of color, and any other groups that have been the target of unfair or unlawful treatment. As part of this work, UFW is a national leader in the movement for immigration reform and immigrants’ rights.

176. UFW has approximately 10,000 members. California is home to more UFW members than any other state, with members in counties across the Central District of California, such as Los Angeles County, Orange County, Riverside County, Ventura County, and San Bernardino County. UFW membership is voluntary and consists of various categories of members. Among these, contributing or associate members are individuals who make a monthly or annual contribution of a designated amount to UFW. Dues-paying members are those who benefit from a UFW collective bargaining agreement.

177. UFW members play an important role in deciding what activities UFW engages in as an organization. At the UFW’s quadrennial Constitutional Convention, members introduce and vote on motions to govern and guide the union’s work, and to elect the Union Executive Board. On an ongoing basis, UFW members respond to surveys, provide feedback, and participate in advisory meetings (known as “consejo de base” in Spanish) to actively participate in the Union’s decisions. UFW has created various programs in response to members’ feedback and requests.

178. UFW membership comes with a variety of benefits. Dues-paying members receive protections from collective bargaining in which UFW engages on their behalf. Contributing or associate members (also called “direct” members) receive UFW photographic identification, accidental life insurance of $4,000, access to UFW discounts with private businesses, and other benefits. For services that prioritize agricultural workers, UFW direct membership establishes membership.

179. UFW brings this action on behalf of its members. UFW’s members have been harmed by the ongoing immigration raids in Southern California and fear being subjected to unlawful stops, arrests, and detention practices in the future. At least one UFW member—Angel—has been subjected to Defendants’ stop and arrest practices.

180. Despite UFW’s lawsuit against DHS and the Border Patrol, filed on February 26, 2025,90 these concerns remain today.

181. Many UFW members, regardless of the stability or permanence of their immigration status, fear that immigration agents will continue to subject farm workers and day laborers to unlawful immigration stops and arrests, especially those who appear non-white. These members face irreparable harm from Defendants’ unlawful practices.

Plaintiff the Coalition for Humane Immigrant Rights (CHIRLA)

182. CHIRLA was founded in 1986, and its mission is to advance the human and civil rights of immigrants and refugees. CHIRLA ensures immigrant communities are fully integrated into our society with full rights and access to resources.

183. As a membership organization, CHIRLA has approximately 50,000 members across California, including both U.S. citizens and noncitizens of varying immigration status. CHIRLA has members in every county in this District. Many of CHIRLA members are day laborers, car wash workers, and street vendors. CHIRLA’s membership is predominantly Latino.

184. CHIRLA is the largest statewide immigrant rights organization in California, with over 185 staff members who provide services to thousands of Californians each year. Its legal department has assisted approximately 30,000 people with direct services and legal education, including numerous CHIRLA members.

185. Some of CHIRLA’s members pay dues to the organization, and those dues help fund the organization’s operations. Other CHIRLA members have become members by virtue of their participation in the organization’s meetings, programs, and policy campaigns.

186. CHIRLA’s members regularly meet with each other in regional committees. Committee meetings can range from a small handful of people to hundreds. In addition, CHIRLA’s student members hold regional statewide conference calls and meetings throughout the year. During these meetings, CHIRLA’s members plan local advocacy campaigns, share information, and discuss issues that affect them, their families, and their local communities. Information from these meetings is reported to CHIRLA’s leadership and used to guide CHIRLA’s programmatic agenda.

187. CHIRLA also holds quarterly membership retreats at which coreleaders discuss issues they are seeing in their communities and set priorities for the organization.

188. CHIRLA also coordinates the Los Angeles Rapid Response Network (LARRN) and educates its membership as well as the broader community through know your rights programming, workshops, social media, and educational literature about a variety of social services and benefits, including immigration law, financial literacy, workers’ rights, and civic engagement. CHIRLA is often a first point of contact for individuals seeking direct assistance and accurate information about policy changes impacting immigrants.

189. CHIRLA brings this action on behalf of its members who reasonably fear being subject to the stop and arrest practices challenged in this case and subsequent detention at B-18. Since immigration authorities began arresting and detaining predominately Latino people across Southern California, including in places where CHIRLA members live and go, they have become terrified that they too will be taken from their families and communities. Indeed, some CHIRLA members, including those with legal status, have begun carrying around their passports, have refrained from being at bus stops, and have reduced how much they go out in public because they are afraid of being stopped and detained unlawfully.

190. As a result of Defendants’ actions, CHIRLA’s mission to serve the immigrant community, including through the provision of legal advice and services, is being frustrated. Throughout the last month, CHIRLA’s attorneys and representatives have attempted to communicate with individuals at B-18, were denied access, and were thwarted in their efforts to offer legal advice to even those detainees they saw at a distance as government officials used car horns to drown them out. Defendants’ actions are also thwarting CHIRLA’s work to coordinate the LARRN as other attorneys and representatives summoned by CHIRLA to B-18 have been similarly denied access.


Plaintiff Immigrant Defenders Law Center (ImmDef)

191. ImmDef was founded in 2015 with the mission of protecting the due process rights of immigrants facing deportation. At its inception, it sought to achieve this goal through implementation of the universal representation model—i.e., ensuring that every immigrant appearing before the immigration court was represented by an attorney. ImmDef is now the largest removal defense nonprofit organization in Southern California, providing full-scale deportation defense, legal representation, legal education, and social services to approximately 30,150 detained and non-detained children and adults annually.

192. ImmDef’s Welcoming Project provides “Know Your Rights” trainings throughout ImmDef’s service area, which includes the counties of Los Angeles, Orange, Kern, Riverside, San Bernardino, and San Diego. These trainings aim to educate immigrant community members about the immigration system and about their due process and civil rights.

193. ImmDef’s Rapid Response team is also part of LARRN, with CHIRLA, and monitors a hotline and responds to notifications about individuals detained in enforcement actions. When possible, ImmDef takes referrals to represent detained individuals in their removal proceedings within ImmDef’s service area. If ImmDef is unable to represent an individual referred through LARRN, ImmDef attempts to connect that individual with pro bono representation.

194. ImmDef’s attorneys and representatives have been denied access to people in detention, including those being held at B-18. As a result of Defendants’ actions, ImmDef’s mission to serve the immigrant community, including through the provision of legal advice and services, is being fundamentally frustrated.

J. Defendants’ Illegal Conduct Will Continue if Not Enjoined

195. The federal government has repeatedly made clear its intent to continue its operations and unlawful stops, arrests, and detentions. Defendants have been candid about their determination to continue pursuing these unlawful policies and practices, unless this Court enjoins them from doing so.

196. Indeed, federal officials have been open about the ongoing and expanding nature of these unlawful immigration raids.

197. White House official Tom Homan recently maligned Los Angeles as a sanctuary city and vowed, “We’re going to send a whole boatload of agents. . . . We’re going to swamp the city.91 He has stated, “This operation is not going to end,”92 and, “Every day in LA we’re going to enforce immigration law. I don’t care if they like it or not.”93 Kristi Noem has also said, “We’re going to stay here and build our operations until we make sure that we liberate the city of Los Angeles.”94 Noem told agents “your performance will be judged every day by how many arrests you, your teammates and your office are able to effectuate. Failure is not an option.”95

198. While immigration enforcement may be done lawfully, these statements demonstrate a commitment to continue operations at any cost, including at the expense of individuals’ constitutional and legal rights. Plaintiffs have already been harmed, and they face a reasonable likelihood of continuing harm, as a result of Defendants’ unlawful policies and practices described herein. Plaintiffs have no plain, adequate, or complete remedy at law to address the wrongs described herein. Injunctive and declaratory relief is necessary to redress their ongoing injuries.

CLASS ACTION ALLEGATIONS

199. The Stop/Arrest Plaintiffs bring this action on behalf of themselves, and in the case of the organizational Stop/Arrest Plaintiffs, their members. In addition, the Stop/Arrest Plaintiffs bring this action under Federal Rules of Civil Procedure 23(a) and (b)(2), on behalf of classes of persons similarly situated to themselves and their members. Plaintiffs seek to represent three classes of individuals who have been or will be subjected to several of the unlawful practices this lawsuit challenges: suspicionless stops; warrantless arrests without evaluations of flight risk; and the failure to identify authority and the reason for arrest.

The Suspicionless Stop Class

The Stop/Arrest Plaintiffs seek to represent a class under Federal Rules of Civil Procedure 23(b)(2) consisting of:

All persons who, since June 6, 2025, have been or will be subjected to a detentive stop by federal agents in this District without a pre-stop, individualized assessment of reasonable suspicion concerning whether the person (1) is engaged in an offense against the United States or (2) is a noncitizen unlawfully in the United States.


200. Numerosity. The proposed class meets the numerosity requirements of Rule 23(a)(1) because it consists of a large number of similarly situated individuals located within this District, such that joinder of all members of the class is impracticable. Although the number of individuals who have been or will be subject to unconstitutional detentive stops by federal agents is not known with precision, class members number in the thousands. Since June 6, 2025, federal agents have arrested more than 1,500 people within the District, and likely conducted unconstitutional detentive stops on many more.

201. Common Questions of Law and Fact. The proposed class meets the commonality requirements of Rule 23(a)(2) because all members of the proposed class have been or will be subjected to the same unconstitutional practices. Thus, there are numerous questions of law and fact common to the proposed class, which predominate over any individual questions, including:

(a) Whether Defendants have a policy, pattern, or practice of conducting stops without regard to whether reasonable suspicion exists that the person

(1) is engaged in an offense against the United States or (2) is a noncitizen unlawfully in the United States; and

(b) Whether Defendants’ policy, pattern, or practice of conducting stops without regard to whether reasonable suspicion exists that the person (1) is engaged in an offense against the United States or (2) is a noncitizen unlawfully in the United States violates the Fourth Amendment or applicable regulations.

The Warrantless Arrest Class

202. The organizational Stop/Arrest Plaintiffs—LAWCN, UFW, and CHIRLA—also seek to represent a class consisting of:

All persons, since June 6, 2025, who have been arrested or will be arrested in this District by federal agents without a warrant and without a pre-arrest, individualized assessment of probable cause that the person poses a flight risk.


203. Numerosity. The proposed class meets the numerosity requirements of Rule 23(a)(1) because it consists of a large number of similarly situated individuals located within this District, such that joinder of all members of the class is impracticable. Although the number of individuals who have been or will be subject to unlawful warrantless arrests by Defendants is not known with precision, class members number in the thousands. Since June 6, 2025, federal agents have arrested more than 1,500 people within the District, with no indications of possessing a warrant or conducting any sort of pre-arrest, individualized assessment of probable cause that the person poses a flight risk.

204. Common Questions of Law and Fact. The proposed class meets the commonality requirements of Rule 23(a)(2) because all members of the proposed class have been or will be subjected to the same unconstitutional practices. Thus, there are numerous questions of law and fact common to the proposed class, which predominate over any individual questions, including:

(a) Whether Defendants have a policy, pattern, or practice of conducting warrantless arrests without probable cause that an individual is likely to escape before a warrant can be obtained for the arrest;

(b) Whether Defendants’ policy, pattern, or practice of conducting stops without probable cause that an individual is likely to escape before a warrant can be obtained for the arrest violates 8 U.S.C. § 1357(a)(2); and

(c) Whether Defendants’ policy, pattern, or practice of conducting stops without probable cause that an individual is likely to escape before a warrant can be obtained for the arrest violates 8 C.F.R. § 287.8(c)(2)(ii).
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Part 3 of 3

The Failure to Identify Class

205. The organizational Stop/Arrest Plaintiffs—LAWCN, UFW, and CHIRLA—also seek to represent a class consisting of:

All persons who, since June 6, 2025, have been arrested or will be arrested in this District by federal agents, where agents (1) fail to identify as an immigration officer who is authorized to execute an arrest, and/or (2) fail to state that person is under arrest and the reason for arrest, after it is practical and safe to do so.


206. Numerosity. The proposed class meets the numerosity requirements of Rule 23(a)(1) because it consists of a large number of similarly situated individuals located within this District, such that joinder of all members of the class is impracticable. Although the number of individuals who have been or will be subject to unlawful arrests in which agents failed to identify themselves in the manner required by law is not known with precision, class members number in the thousands. Since June 6, 2025, federal agents have arrested more than 1,500 people within the District, and it has been widely reported that Defendants do not generally identify themselves during these arrests. 207. Common Questions of Law and Fact. The proposed class meets the commonality requirements of Rule 23(a)(2) because all members of the proposed class have been or will be subjected to the same unconstitutional practices. Thus, there are numerous questions of law and fact common to the proposed class, which predominate over any individual questions, including:

(a) Whether Defendants have a policy, pattern, or practice of (1) failing to (1) identify as an immigration officer who is authorized to execute an arrest, or (2) failing to state that person is under arrest and the reason for arrest, after it is practical and safe to do so; and

(b) Whether Defendants’ policy, pattern, or practice of (1) failing to identify as an immigration officer who is authorized to execute an arrest, or (2) failing to state that person is under arrest and the reason for arrest, after it is practical and safe to do so violates 8 C.F.R. § 287.8(c)(2)(iii).

Allegations Common to All Classes

208. The proposed classes satisfy the requirements of Federal Rule of Civil Procedure 23(a)(1) because they are sufficiently numerous so as to make joinder impracticable.

209. Joinder is also impractical because the proposed class includes individuals who will be subject to Defendants’ unlawful practices in the future and therefore cannot be joined.

210. Typicality. The proposed classes further meet the typicality requirement of Federal Rule of Civil Procedure 23(a)(3). Plaintiffs’ legal claims are typical to all members of the proposed classes. Plaintiffs have no interests separate from those of the classes they seek to represent, and seek no relief other than the relief sought on behalf of each class. Defendants have acted and intend to act in a manner adverse to the rights of the Suspicionless Stops Class and the Warrantless Arrest Class, making final injunctive and declaratory relief appropriate with regard to each class as a whole.

211. Propriety of Class Action Mechanism. The prosecution of individual actions against Defendants by individual members of the proposed class would be inefficient and create a risk of inconsistent and varying adjudications.

212. Adequacy of Class Representation. The proposed classes meet the adequacy requirements of Federal Rule of Civil Procedure 23(a)(4). Each putative class representative has committed to fairly and adequately representing the interests of the Suspicionless Search Class, the Warrantless Arrest Class, and the Failure to Identify Class. Plaintiffs know of no conflict between their interests and those of the proposed class and, in fact, seek relief identical to the relief sought by all class members.

213. Adequacy of Counsel for the Class. The Stop/Arrest Plaintiffs’ counsel are experienced in class action, civil rights, and immigrants’ rights litigation. Plaintiffs’ counsel have the requisite level of expertise to adequately prosecute this case on behalf of Plaintiffs and the proposed classes. Plaintiffs’ counsel will fairly and adequately represent the interests of each class.

214. Finally, the proposed classes satisfy Rule 23(b)(2) because Defendants have acted on grounds generally applicable to the class, thereby making equitable relief appropriate with respect to the class as a whole.

CAUSES OF ACTION

COUNT ONE

Violation of Fourth Amendment: Unreasonable Seizures On Behalf of the Stop/Arrest Plaintiffs and the Suspicionless Stop Class Against All Defendants


215. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

216. Except at the border and its functional equivalents, the Fourth Amendment prohibits Defendants from conducting a detentive stop to question a person without reasonable suspicion that a person is a noncitizen unlawfully in the United States.

217. “A person’s mere propinquity to others independently suspected of [unlawful] activity does not, without more, give rise to probable cause to search [or seize] that person.” Perez Cruz v. Barr, 926 F.3d 1128, 1138 (9th Cir. 2019) (quotation omitted). “‘Reasonable suspicion’ is no different.” Id.

218. Defendants have a policy, pattern, and practice of stopping individuals without regard to reasonable suspicion that they are unlawfully in the United States.

219. As a part of Defendants’ policy, pattern, and practice, when conducting stops, Defendants engage in a show of force so overwhelming that a reasonable person would not feel free to leave. As a matter of policy, pattern, and practice, Defendants do not evaluate the need for force or tailor the force they use to the circumstances of individual stops and arrests.

220. Defendants’ policy, pattern, and practice violates the Fourth Amendment to the U.S. Constitution.

COUNT TWO

Violation of 8 U.S.C. § 1357(a)(2)
Warrantless Arrests Without Probable Cause of Flight Risk
On Behalf of Plaintiffs LAWCN, UFW, CHIRLA, and the Warrantless Arrest Class
Against All Defendants


221. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.


222. 8 U.S.C. § 1357(a)(2) requires that arrests without a warrant be accompanied by “reason to believe” that an individual is “likely to escape before a warrant can be obtained for [their] arrest.”

223. Defendants have a policy, pattern, and practice of making arrests without any warrant without making an individualized determination of flight risk. They have no mechanism for ensuring compliance with the statutory limits of agents’ and officers’ warrantless arrest authority and do not provide guidance to agents and officers on how to make an individualized determination of likelihood of escape. Defendants permit agents and officers to make warrantless arrests carte blanche in violation of law.

224. Defendants’ policy, pattern, and/or practice of making warrantless arrests without the required individualized flight risk analysis is “final agency action” that is “in excess of statutory jurisdiction, authority, or limitations” under 8 U.S.C. § 1357(a)(2). 5 U.S.C. §§ 704, 706(2)(C).

225. Separate from the APA, Defendants’ policy, pattern, and practice of making warrantless arrests without the required individualized flight risk analysis is ultra vires.


COUNT THREE
Violation of 8 C.F.R. § 287.8(c)(2)(ii)
Standards for Stops and Warrantless Arrests
On Behalf of Plaintiffs LAWCN, UFW, CHIRLA, and the Warrantless Arrest Class
Against All Defendants


226. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

227. Defendants are bound by regulation to conform warrantless arrests to the standards in 8 C.F.R. § 287.8(c), including the requirement at 8 C.F.R. § 287.8(c)(2)(ii) that officers have reason to believe that an individual is “likely to escape before a warrant can be obtained.”

228. Defendants have a policy, pattern, and practice of making arrests without any warrant without making an individualized determination of flight risk. They have no mechanism for ensuring compliance with the regulatory limits of agents’ and officers’ warrantless arrest authority and do not provide guidance to agents and officers on how to make an individualized determination of likelihood of escape. Defendants permit agents and officers to make warrantless arrests carte blanche in violation of law.

229. Defendants’ policy, pattern, and practice is “final agency action” that is “in excess of statutory jurisdiction, authority, or limitations” under 8 C.F.R. § 287.8(c)(2)(ii). 5 U.S.C. §§ 704, 706(2)(C).

COUNT FOUR
Violation of 8 C.F.R. § 287.8(c)(2)(iii)
Failure to Identify Authority and Reason for Arrest
On Behalf of Plaintiffs LAWCN, UFW, CHIRLA
Against All Defendants


230. Plaintiffs incorporate the allegations in the paragraphs above as though fully set forth here.

231. The regulations require agents and officers, at the time of an arrest or as soon as it is practicable and safe to do so, to identify themselves as “an immigration officer who is authorized to execute an arrest” and “state that the person is under arrest and the reason for the arrest.” 8 C.F.R. § 287.8(c)(3).

232. Defendants have a policy, pattern, and practice of not timely identifying themselves, their authority to execute an immigration arrest, or the reasons for an arrest.

233. Defendants’ policy, pattern, and practice is a “final agency action” that is “in excess of statutory jurisdiction, authority, or limitations” under 8 C.F.R. § 287.8(c)(2)(ii). 5 U.S.C. §§ 704, 706(2)(C).

COUNT FIVE
Violation of the Fifth Amendment: Access to Counsel
On Behalf of the Access/Conditions Plaintiffs
Against Defendants Noem, Lyons, and Santacruz Jr.


234. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

235. Individuals detained at B-18 have the right to hire and consult with attorneys. Due process also requires that detainees have adequate opportunities to obtain counsel and to visit and communicate with counsel once counsel is retained. Defendants have a policy, pattern, and practice of turning away attorneys at the door of B-18 and depriving detainees of access to confidential legal consultations by phone. This lack of counsel has severe consequences. Detainees are forced to interact with federal immigration officials without the benefit of legal advice even though it is readily available.

236. Defendants’ actions violate the Fifth Amendment.

COUNT SIX
Violation of 8 U.S.C. § 1362
Access to Counsel
On Behalf of the Access/Conditions Plaintiffs
Against Defendants Noem, Lyons, and Santacruz Jr.


237. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

238. The Immigration and Nationality Act (INA) guarantees noncitizens the right to counsel in connection with inadmissibility and deportability proceedings. 8 U.S.C. §1362; see also 8 U.S.C. § 1229a(b)(4)(A); Colmenar v. INS, 210 F.3d 967, 971 (9th Cir. 2000); Orantes-Hernandez, 919 F.2d at 564.

239. This protection necessarily entails the right to consult with an attorney in advance of any hearing—especially a hearing at which a noncitizen faces potentially permanent banishment from the United States. Rios-Berrios, 776 F.2d at 862. The same substantive standards that protect the Plaintiffs’ right to counsel under the Due Process Clause apply to their statutory rights under the INA. See Agyeman v. INS, 296 F.3d 871, 877 (9th Cir. 2002) (“If a[] [noncitizen] is prejudiced by a denial of any of the applicable procedural protections, he is denied his constitutional guarantee of due process.”).

240. Defendants have a policy, pattern, and practice of turning away attorneys at the door of B-18 and depriving detainees of access to confidential legal consultations by phone. This lack of counsel has severe consequences. Detainees are forced to interact with federal immigration officials without the benefit of legal advice even though it is readily available.

241. Defendants’ policy, pattern, and practice of denying detained individuals access to legal advice is “final agency action” that is in excess of statutory authority. See 5 U.S.C. §§ 704, 706(2)(C).

COUNT SEVEN
Violation of the Fifth Amendment: Conditions of Confinement
On Behalf of the Access/Conditions Plaintiffs
Against Defendants Noem, Lyons, and Santacruz Jr.


242. Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

243. Civil detainees’ conditions of confinement are unconstitutional if they “amount to punishment.” Bell v. Wolfish, 441 U.S. 520, 535 (1979).

244. Defendants have allowed conditions to deteriorate at B-18 to an extent that they amount to punishment. They have failed to provide basic necessities like food, water, adequate hygiene facilities, and medical care. Defendants have also violated detainees’ constitutional right to due process by subjecting them to overcrowding and failing to provide adequate sleeping accommodations at B-18.Defendants’ ongoing violations of the Fifth Amendment directly harm CHIRLA and ImmDef’s missions to provide legal services and assistance to community members, and harm CHIRLA members who will be subject to detentions at B-18 by depriving them of their fundamental right to an “appropriate place of detention,” and serving to coerce some detained individuals into accepting voluntary departure before they have an opportunity to consult counsel.


COUNT EIGHT Violation of Fifth Amendment: Due Process
On Behalf of Petitioner-Plaintiffs Perdomo, Osorto, and Molina
Against Defendants Noem, Lyons, and Santacruz Jr.


245. Petitioners-Plaintiffs repeat, re-allege, and incorporate by reference each and every allegation in the preceding paragraphs as if fully set forth herein.

246. The government may not deprive a person of life, liberty, or property without due process of law. U.S. Const. amend. V. “Freedom from imprisonment—from government custody, detention, or other forms of physical restraint—lies at the heart of the liberty that the Clause protects.” Zadvydas v. Davis, 533 U.S. 678, 690 (2001).

247. The government’s detention of Petitioners-Plaintiffs violates their rights to due process because they have been detained without lawful authority, infringing on their fundamental right to liberty.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray that this Court grant the following relief:

(1) Assume jurisdiction over this matter;

(2) Certify this action as a class action pursuant to Federal Rule of Civil Procedure 23(b)(2);

(3) Appoint the counsel for Stop/Arrest Plaintiffs as class counsel pursuant to Federal Rule of Civil Procedure 23(g);

(4) Declare that Defendants’ policy, pattern, and practice of conducting stops without reasonable suspicion violate the Fourth Amendment of the United States Constitution;

(5) Declare that Defendants’ policy, pattern, and practice of making warrantless arrests without individualized flight risk determinations violate 8 U.S.C. § 1357(a)(2); 8 C.F.R. § 287.8(c)(2)(ii); and the APA;

(6) Declare that Defendants’ policy, pattern, and practice of failing to identify the authority and reasons for arrests violate 8 C.F.R. § 287.8(c)(2)(iii); and the APA;

(7) Declare that Defendants’ denial of access to counsel violates the Due Process Clause of the Fifth Amendment of the United States Constitution;

(8) Declare that Defendants’ policy and practice of denying access to counsel violate the rights of the Access/Detention Plaintiffs under 8 U.S.C. § 1362 and the APA;

(9) Declare that the conditions of confinement imposed by Defendants at B-18 violate the Fifth Amendment of the United States Constitution;

(10) Issue a preliminary and permanent injunction enjoining further violations of Plaintiffs’ rights;

(11) Vacate Defendants’ unlawful policies and practices that violate statutory and regulatory law under the APA;

(12) Enjoin Defendants from transferring Petitioner-Plaintiffs outside of this judicial district during the pendency of removal proceedings;

(13) Enjoin Defendants from removing Petitioner-Plaintiffs from the United States without the procedures for removal identified in the INA;

(14) Order the immediate release of Petitioner/Plaintiffs pending these proceedings;

(15) Award reasonable attorneys’ fees, costs, and other disbursements permitted under the Equal Access to Justice Act, 28 U.S.C. § 2412, and any other applicable statute, and;

(16) Order any and all such other relief as the Court deems just, equitable, and proper.

DATED: July 1, 2025

Respectfully submitted,

By: /s/ Stacy Tolchin
Stacy Tolchin
Attorneys for Stop/Arrest Plaintiffs

By: /s/ Mohammad Tajsar
Mohammad Tajsar
Attorney for Stop/Arrest Plaintiffs

By: /s/ Mark Rosenbaum
Mark Rosenbaum
Attorney for Plaintiffs

_______________

Notes:

1 Jennie Taer, Trump admin’s 3,000 ICE arrests per day quota is taking focus off criminals and ‘killing morale’: insiders, New York Post (June 17, 2025), https://nypost.com/2025/06/17/us-news/t ... -insiders/.

2 Elizabeth Findell, et al., The White House Marching Orders That Sparked the L.A. Migrant Crackdown, The Wall Street Journal (June 9, 2025), https://www.wsj.com/us-news/protests-lo ... p-f5089877.

3 Id.

4 Dep’t of Homeland Sec., ICE Captures Worst of the Worst Illegal Alien Criminals in Los Angeles Including Murderers, Sex Offenders, and Other Violent Criminals (June 8, 2025), https://www.dhs.gov/news/2025/06/08/ice ... -murderers

5 Rachel Uranga, “Most nabbed in L.A. raids were men with no criminal conviction, picked up off street,” L.A. Times (June 24, 2025), https://www.latimes.com/california/stor ... nal-record.

6 Brittany Mejia & Rachel Uranga, Fears of racial profiling rise as Border Patrol conducts ‘roving patrols,’ detains U.S. Citizens, L.A. Times (June 15, 2025), https://www.latimes.com/california/stor ... s-targeted

7 Kaitlyn Huamani, Home Depot caught in the crosshairs of L.A. immigration raids, L.A. Times (June 9, 2025), https://www.latimes.com/business/story/ ... ions-raids (discussing how Home Depots across Southern California have been impacted by the immigration raids); Maanvi Singh, At Home Depot, Ice raids terrorize the workers who helped build LA: “They just come and grab you”, The Guardian (June 16, 2025), https://www.theguardian.com/us-news/202 ... s-angeles; Pat Maio, Home Depot’s day laborer haven turns into immigration target across Southern California, L.A. Daily News (June 13, 2025), https://www.dailynews.com/2025/06/13/ho ... nia-raids/ (listing multiple Home Depot locations in Los Angeles and Orange County where day laborers have been detained).

8 Cameron Kiszla, Immigration agents raid several L.A. businesses, encounter protesters, KTLA 5 (June 6, 2025), https://ktla.com/news/local-news/federa ... -district/ (reporting that masked officers wearing vests emblazoned with “HSI” took individuals into custody at a Home Depot in Westlake); Helen Jeong, 45 people arrested during ICE raids at 3 downtown LA locations, NBC 4 (June 6, 2025), Telemundo 52, Actividad de autoridades federales en distintas areas de Los Angeles, YouTube (June 7, 2025), https://www.youtube.com/watch?v=y-MrC5tzd3o (featuring a day laborer witness who recalled hearing someone yell “la migra, la migra!” and observed officers arrest several day laborers without presenting any documents or warrants; the entire operation reportedly lasted only 20 minutes).

9 Kaitlyn Huamani, Home Depot caught in the crosshairs of L.A. immigration raids, L.A. Times (June 9, 2025), https://www.latimes.com/business/story/ ... ions-raids (noting an immigration raid conducted by federal agents at a Home Depot in Whittier); Maanvi Singh, At Home Depot, Ice raids terrorize the workers who helped build LA: “They just come and grab you”, The Guardian (June 16, 2025), https://www.theguardian.com/us-news/202 ... os-angeles (same); Tracey Leong & Karla Rendon, ‘Hope he comes back.’ Long Beach family says father detained outside Whittier Home Depot, NBC 4 (Jun, 14, 2025), https://www.nbclosangeles.com/news/loca ... n/3724461/ (highlighting the emotional impact of immigration raids on a Long Beach family after a loved one was detained outside the Whittier Home Depot).

10 Pat Maio, supra, note 7; Nathan Solis, et al., What businesses are the feds targeting during L.A. immigration sweeps? Here’s what we know, L.A. Times (June 10, 2025), https://www.latimes.com/california/stor ... at-we-know.

11 Pat Maio, supra, note 7; Nathan Solis, supra, note 10.

12 Karla Rendon, Immigration raids reported near Downey churches, NBC 4 (June 11, 2025), https://www.nbclosangeles.com/news/loca ... s/3721686/.

13 Helen Jeong, ICE agents fail to detain day laborers at Upland Home Depot after bystanders intervene, NBC 4 (June 16, 2025), https://www.nbclosangeles.com/news/loca ... e/3725645/.

14 Pat Maio, supra, note 7.

15 Brittny Mejia & Rachel Uranga, Raid at a Home Depot in Hollywood shatters an immigrant refuge, L.A. Times (June 20, 2025), https://www.latimes.com/california/stor ... home-depot.

16 Pat Maio, supra, note 7.

17 NBCLA, Federal agents detain people near Hollywood Home Depot, YouTube (June 19, 2025), https://www.youtube.com/watch?v=sjCJYBR24gw.

18 Baldwin Park Among Cities Targeted in Immigration Raids Wednesday Morning, Baldwin Park News (June 29, 2025), https://baldwinparknewsonline.com/baldw ... y-morning/.

19 Semantha Raquel Norris, Federal Immigration Agents Terrorize the Northeast Valley, San Fernando Valley Sun (June 19, 2025), https://sanfernandosun.com/2025/06/19/f ... st-valley/.

20 209 Drone Shots (@209_drone_shots), Instagram (June 27, 2025), https://www.instagram.com/p/DLZCN6TOHoW.

21 NBC San Diego (@nbcsandiego), Instagram (June 28, 2025, https://www.instagram.com/p/DLP893MsqS6/

22 Unión Del Barrio (@uniondelbarrio), Instagram (June 26, 2025), https://www.instagram.com/p/DLYF94bBUYs.

23 Eric Villagomez (@puroslatinotx), Instagram (June 8, 2025), https://www.instagram.com/p/DKqboCRptBU.

24 Eric Villagomez (@purolatinostv), Instagram (June 6, 2025), https://www.instagram.com/p/DKkr84sBSgX.

25 Pico Rivera, California (@picoriveracommunity), Instagram (June 17, 2025), https://www.instagram.com/p/DLA7wZYzlKY; Fox 11 Los Angeles, Adrian Martinez: Young man detained by ICE outside a Walmart in Pico Rivera, YouTube (June 17, 2025), https://www.youtube.com/watch?v=iZ6J99cnYqs.

26 Emily Baumgaertner Nunn & Anushka Patil, Carwashes become easy targets in California’s ICE raids, N.Y. Times (June 11, 2025), https://www.nytimes.com/live/2025/06/11 ... ice-raids; Suhauna Hussain, ‘They are grabbing people.’ L.A. and Orange County car wash workers targeted by federal immigration raids, L.A. Times (June 11, 2025), https://www.latimes.com/business/story/ ... -ice-raids.

27 Amy Taxin & Dorany Pineda, Immigration Raids are threatening businesses that supply America’s food, farm bureaus say, Associated Press (June 13, 2025), https://www.kvpr.org/local-news/2025-06 ... ureaus-say.

28 Génesis Miranda Miramontes, US Attorney confirms FBI, federal agencies serve a search warrant in downtown LA, NBC 4 (June 6, 2025), https://www.nbclosangeles.com/news/loca ... s/3717411/.

29 Leanne Suter, Community members try to help street vendor taken by federal agents in Ladera Heights, video shows, ABC7 (June 27, 2025), https://abc7.com/post/community-members ... /16863236/.

30 See, e.g., Ryan P. Cruz, Immigration Enforcement Shakes Up Communities of Santa Barbara County, Santa Barbara Independent (June 20, 2025), https://www.independent.com/2025/06/20/ ... ra-county/.

31 See, e.g., Brittny Mejia, Video shows immigration agents interrogating a Latino U.S. citizen: ‘I’m American, bro!’, L.A. Times (June 13, 2025), https://www.latimes.com/politics/story/ ... erican-bro.


32 Al Rojo Vivo, Agentes federales realizan redadas en zona industrial de California, (June 14, 2025), https://www.youtube.com/watch?v=TXMlJqmME0U (reporting that at least two women leaving work at packing house, along with one woman’s son who had gone to pick her up, were detained during an immigration raid).

33 Josh Dubose, Dozens of heavily armed ICE agents swarm popular L.A. County swap meet, KTLA 5 (June 15, 2025), https://ktla.com/news/local-news/dozens ... wap-meet/; Jasmine Mendez, et al., Immigration raids continue as Trump appears to soften on targeting some workplaces, L.A. Times (June 15, 2025), https://www.latimes.com/california/stor ... s-continue (“If you looked Hispanic in any way, they just took you.”); Tim Pulliam & Amanda Palacios, Several people taken into custody during immigration raid at Santa Fe Springs Swap Meet, ABC 7 (June 16, 2025), https://abc7.com/post/several-people-ta ... 16753752/; Levi Sumagaysay & Lauren Hepler, From San Diego to the Bay Area, California Restaurants are on Edge Over Immigration Raids, CalMatters (June 19, 2025), https://calmatters.org/economy/2025/06/ ... ion-raids/.

34 Sophie Flay, ICE agents detain several people at Pasadena bus stop, conducts raids across the city, ABC 7 (June 19, 2025), https://abc7.com/post/ice-agents-detain ... /16785979/.

35 Douglas Saunders Sr., OC attorney says she was detained in ICE raid at Santa Ana park, Daily Journal (June 19, 2025), https://www.dailyjournal.com/articles/3 ... the%20area (detailing how a U.S. citizen and Orange County attorney was detained by ICE agents while walking at a park.)

36 Ricardo Tovar, LA County Officials Say ICE Agents Targeted Individuals at Churches, KSBW8 (June 12, 2025), https://www.ksbw.com/article/la-county- ... h/65039805 (“A council member confirmed that ICE conducted raids at a Home Depot, LA Fitness, and inside and outside of two churches in the city.”); Union del Barrio (@uniondelbarrio), Instagram (June 11, 2025), https://www.instagram.com/p/DKxKR5AIOUq/.

37 Vicent Medina, Tensions high as immigration sweeps reach Downey churches, The Downey Patriot (June 16, 2025), https://www.thedowneypatriot.com/articl ... y-churches.

38 Raids in Southern California rattle immigrant communities – including those in the US legally, The Tribune (June 11, 2025), https://tribtown.com/2025/06/11/raids-i ... s-legally/.

39 Travis Schlepp, ICE agents make arrest at Los Angeles area church, KTLA 5 (June 11, 2025), https://ktla.com/news/local-news/ice-ag ... king%20lot.

40 Josh Dubose, supra, note 33.

41 Id.

42 Id.

43 Douglas Saunders Sr., OC Attorney Says She Was Detained in ICE Raid at Santa Ana Park, Daily Journal (June 19, 2025), https://www.dailyjournal.com/articles/3 ... a-ana-park.

44 Dani Anguiano, US Citizen Arrested During ICE Raid in What Family Describes as ‘Kidnapping,” The Guardian (June 26, 2025), https://www.theguardian.com/us-news/202 ... drea-velez.

45 Josh DuBose, supra, note 33.

46 Alicia A. Caldwell, Stun grenades, armored trucks in ICE raids spur tensions, Bloomberg (June 6, 2025), https://www.bloomberg.com/news/articles ... =undefined.


47 L.A. Times, Unidentified agents detain L.A. fruit vendor: ‘Like he’d been kidnapped’, L.A. Times (June 12, 2025), https://www.latimes.com/00000197-61d1-d ... 1d0000-123.

48 Id.

49 Dani Anguiano, et al., ‘Snatching off the streets’: Ice targets churches, car washes and workplaces, The Guardian (June 12, 2025), https://www.theguardian.com/us-news/202 ... -ice-raids.

50 Id.

51 Id.

52 Hetty Change & Jonathon Lloyd, Day laborers targeted in raid at Santa Ana Home Depot, OC officials say, NBC 4 (June 10, 2025), https://www.nbclosangeles.com/news/loca ... id/3720487.

53 Jesus Jiménez & Emily Baumgaertner Nunn, Church Leaders Shaken After a Man was Detained in Their Parking Lot, N.Y. Times (June 11, 2025), https://www.nytimes.com/2025/06/11/us/l ... rrest.html.


54 Jesus Jiménez & Emily Baumgaertner Nunn, Church Leaders Shaken After a Man was Detained in Their Parking Lot, N.Y. Times (June 11, 2025), https://www.nytimes.com/2025/06/11/us/l ... rrest.html.

55 Id.; Travis Schlepp, ICE agents make arrest at Los Angeles area church, KTLA 5 (June 11, 2025), https://ktla.com/news/local-news/ice-ag ... king%20lot.

56 Jesus Jiménez & Emily Baumgaertner Nunn, supra, note 54.

57 Obed Manuel, U.S. Marine veteran says father’s violent arrest by immigration agents was ‘inhumane’, NPR (June 27, 2025), https://www.npr.org/2025/06/27/nx-s1-54 ... ikes%20him

58 Leanne Suter, Community members try to help street vendor taken by federal agents in Ladera Heights, video shows, ABC 7 (June 27, 2025), https://abc7.com/post/community-members ... /16863236/.


59 Benicia Garcia (@ b_b_b_beniandthejets), Instagram (June 26, 2025), https://www.instagram.com/p/DLXk-kSRRy3/.

60 See, e.g., Lily Dallow, L.A. man with previous human smuggling arrest may have been impersonating ICE agent, KTLA 5 (June 27, 2025), https://ktla.com/news/local-news/l-a-ma ... al-agent/; José Olivares, US sees spate of arrests of civilians impersonating Ice officers, The Guardian (June 28, 2025), https://www.theguardian.com/us-news/202 ... e-officers.

61 Arelis R. Hernández, ‘La migra!’: Day laborers recount ICE raid outside Los Angeles Home Depot, The Washington Post (June 8, 2025) https://www.washingtonpost.com/immigrat ... aid-trump/.


62 Debbie Cenziper et. al, Under Trump, ICE aggressively recruited sheriffs as partners to question and detain undocumented immigrants, The Washington Post (Nov. 23, 2021), https://www.washingtonpost.com/investig ... ants-287g/.


63 Photos taken by LARRN attorney Helen Boyer Saturday June 7, 2025 at approx 8:50 AM.

64 Nick Miroff & Maria Sacchetti, Trump Officials Issue Quotas to ICE Officers to Ramp Up Arrests, The Washington Post (last updated Jan. 26, 2025), https://www.washingtonpost.com/immigrat ... ump-quota/.

65 Marianne LeVine, et al., ICE is Arresting Migrants in Worksite Raids. Employers are Largely Escaping Charges, The Washington Post (June 30, 2025), https://www.washingtonpost.com/immigrat ... companies/ (noting an April announcement by ICE officials that the agency had arrested more than 1,000 workers during Trump’s first 100 days and collecting stories of workplace raids across the country); Mark Moran, ICE Detains More than 530 People in Workplace ‘Raids’ in U.S. Northeast, United Press International (Jan. 23, 2025), https://www.upi.com/Top_News/US/2025/01 ... 737692376/.

66 Maanvi Singh & Will Craft, As deportations ramp up, immigrants increasingly fear Ice check-ins: ‘All bets are off’, The Guardian (Apr. 6, 2025), https://www.theguardian.com/us-news/202 ... ice-trump; Nidia Cavazos, Immigrants at ICE check-ins detained, held in basement of federal building in Los Angeles, some overnight, CBS News (June 7, 2025), https://www.cbsnews.com/news/immigrants ... s-angeles/.

67 Julia Ainsley, Trump admin tells immigration judges to dismiss cases in tactic to speed up arrests, NBC News (June 11, 2025), https://www.nbcnews.com/politics/nation ... cna212138; Luis Ferré-Sadurní, Inside a Courthouse, Chaos and Tears as Trump Accelerates Deportations, N.Y. Times (June 12, 2025), https://www.nytimes.com/2025/06/12/nyre ... tion.html; Ximena Bustillo, ICE’s novel strategy allows for more arrests from inside immigration courts, NPR (June 12, 2025), https://www.npr.org/2025/06/12/nx-s1-54 ... s-arrests; Martha Bellisle, et al., Immigration officers intensify arrests in courthouse hallways on a fast track to deportation, AP News (June 11, 2025), https://apnews.com/article/immigration- ... 27895d5ea1 (describing new tactic in which immigration judges grant a government motions dismiss deportation proceedings, enabling ICE officers—often masked—to arrest noncitizens immediately outside in the hallway and place them on an expedited path to removal).

68 Press Release, DHS, Statement from a DHS Spokesperson on Directive Expanding Immigration Law Enforcement to Some Department of Justice Officials (Jan. 23, 2025), https://www.dhs.gov/news/2025/01/23/sta ... nforcement.

69 Nicolae Viorel Butler, Court Forces DHS to Preserve Immigrant Rights Offices, Migrant Insider (May 27, 2025), https://migrantinsider.com/p/court-forc ... -284225192”https://migrantinsider.com/p/court-forces-dhs-to-preserve-immigrant?utm_source=CLINIC%2BMail&utm_campaign=f9e1ee6428-tips-6-2-25&utm_medium=email&utm_term=0_-663ab9ab77-284225192.

70 Press Release, Government Accountability Project, DHS Halted 500+ Civil Rights Investigations When It Shut Down Oversight Office, Whistleblowers Say (May 15, 2025), https://whistleblower.org/press-release ... owers-say/.

71 Press Release, DHS, Statement from a DHS Spokesperson on Directives Expanding Law Enforcement and Ending the Abuse of Humanitarian Parole (Jan. 21, 2025), https://www.dhs.gov/news/2025/01/21/sta ... ding-abuse (noting a directive “rescind[ing] the Biden Administration’s guidelines for . . . enforcement actions that thwart law enforcement in or near so-called “sensitive” areas).

72 Marisa Kabas, ICE agents get green light to make unjustified warrantless arrests, The Handbasket (June 12, 2025), https://www.thehandbasket.co/p/ice-warr ... tanon-nava.

73 Stuard Anderson, Stephen Miller’s Order Likely Sparked Immigration Raids and Protests, Forbes, Jun. 9, 2025, https://www.forbes.com/sites/stuartande ... -protests/.

74 Elizabeth Findell, supra note 2 (reporting that agents were no longer required to develop target lists of noncitizens unlawfully present in the U.S., marking a shift from longstanding policy).

75 José Olivares, US immigration officers ordered to arrest more people even without warrants, The Guardian (June 4, 2025), https://www.theguardian.com/us-news/202 ... al-arrests.

76 José Olivares, US immigration officers ordered to arrest more people even without warrants, The Guardian, (June 4, 2025), https://www.theguardian.com/us-news/202 ... al-arrests.

77 Elizabeth Findell, et al., supra note 2; Julia Ainsley, et al., A sweeping new ICE operation shows how Trump’s focus on immigration is reshaping federal law enforcement, NBC News (June 4, 2025), https://www.nbcnews.com/politics/justic ... rcna193494.

78 Cameron Kiszla, Immigration agents raid several L.A. businesses, encounter protestors, KTLA (June 6, 2025), https://ktla.com/news/local-news/federa ... -district/ (“The FBI confirmed to KTLA that it is participating in the HSI raids, not just in Los Angeles but nationwide, ‘as directed by the Attorney General. As we have been asked to do, we are sending Agents to participate in these immigration enforcement efforts,’ the statement said.”).

79 Press Release, ICE, ICE Los Angeles announces 239 illegal aliens were arrested during recent operation (May 14, 2025), https://www.ice.gov/news/releases/ice-l ... -operation (confirming ATF’s involvement in ICE operations in the Los Angeles area).

80 Id. (confirming DEA’s involvement in ICE operations in the Los Angeles area).

81 Sergio Olmos & Wendy Fry, Border Patrol said it targeted known criminals in Kern County. But it had no record of 77 of 78 arrestees, CalMatters (Apr. 8, 2025), https://calmatters.org/economy/2025/04/ ... rn-county/.

82 Enforcement and Removal Operations, U.S. Immigration & Customs Enforcement, https://www.ice.gov/about-ice/ero (last visited June 30, 2025)

83 See Nava v. DHS, Proposed Settlement Agreement, https://www.aclu-il.org/sites/default/f ... ement.pdf; see also National Immigrant Justice Center, Final Settlement Regarding ICE Warrantless Arrests and Vehicle Stops: Overview of Settlement Requirements and Remedies (last updated Jan. 17, 2025), https://immigrantjustice.org/final-sett ... -remedies/.

84 Marisa Kabas, ICE agents get green light to make unjustified warrantless arrests, The Handbasket (June 12, 2025), https://www.thehandbasket.co/p/ice-warr ... tanon-nava.

85 Hamed Aleaziz & Todd Heisler, Under Pressure From the White House, ICE Seeks New Ways to Ramp Up Arrests, N.Y. Times (June 11, 2025), https://www.nytimes.com/2025/06/11/us/p ... rests.html. Defendants in that case also indicated in a court pleading that they intend to resume ICE knock and talks as of July 1, 2025. Plaintiffs in that case have sought to confirm whether this is still their intent and have not received a response.

86 Complaint, United States v. Javier Ramirez, No. 2:25-MJ-03646-DUTY (C.D. Cal. June 13, 2025); see also Brittny Mejia, supra note 23.

87 Victor M. Gordo, Pasadena Mayor: Trump’s Immigration Raids Hurt Communities Like Mine, Time (June 18, 2025), https://time.com/7295305/pasadena-trump ... tion-raids.

88 Kaitlyn Huamani & Suhauna Hussain, More L.A. car washes targeted in immigration raids, some closed amid fears of further sweeps, L.A. Times (June 20, 2025), https://www.latimes.com/business/story/ ... s-closures.

89 Id.

90 Complaint, UFW v. Noem, No. 1:25-cv-00246 JLT CDB (E.D. Cal. Feb. 26, 2025), https://www.aclusocal.org/sites/default ... plaint.pdf.

91 Jenny Jarvie & Grace Toohey, Trump immigration raids: Stunning, yet predictable, L.A. Times Online (June 15, 2025), https://www.latimes.com/california/stor ... inevitable.

92 Andrea Castillo, ‘We need to find these people’: L.A. immigration raids a sign of what’s to come, officials say, L.A. Times Online (June 12, 2025), https://www.latimes.com/politics/story/ ... icials-say.

93 Jacob Soboroff & Doha Madani, Trump’s border czar threatens arrest for immigration interference, warns Newsom and Bass not to ‘cross that line’, NBC (June 8, 2025), https://www.nbcnews.com/news/us-news/to ... a211701.94 Adrian Florido & Liz Baker, DHS vows immigration raids will continue as resistance mounts, NPR (June 12, 2025), https://www.npr.org/2025/06/12/g-s1-725 ... rotests.95 Tyler Pager, et al., Trump’s Conflicting Messages on Workplace Raids Leave Businesses Reeling, N.Y. Times (June 17, 2025), https://www.nytimes.com/2025/06/17/us/p ... raids.html.

94 Adrian Florido & Liz Baker, DHS vows immigration raids will continue as resistance mounts, NPR (June 12, 2025), https://www.npr.org/2025/06/12/g-s1-725 ... rotests.95 Tyler Pager, et al., Trump’s Conflicting Messages on Workplace Raids Leave Businesses Reeling, N.Y. Times (June 17, 2025), https://www.nytimes.com/2025/06/17/us/p ... raids.html.

95 Tyler Pager, et al., Trump’s Conflicting Messages on Workplace Raids Leave Businesses Reeling, N.Y. Times (June 17, 2025), https://www.nytimes.com/2025/06/17/us/p ... raids.html.
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Tue Jul 15, 2025 9:09 pm

https://www.courtlistener.com/docket/70594806/pedro-vasquez-perdomo-v-kristi-noem/
Pedro Vasquez Perdomo v. Kristi Noem (2:25-cv-05605)
District Court, C.D. California
Last Updated: July 15, 2025, 12:37 p.m.
Assigned To: Maame Ewusi-Mensah Frimpong


https://ia600901.us.archive.org/2/items ... 1.87.0.pdf

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

Pedro Vasquez Perdomo, et al.,
Plaintiffs,
v.
Kristi Noem, et al.,
Defendants

Case No. Case 2:25-cv-05605-MEMF-SP Document 87 Filed 07/11/25

ORDER GRANTING PLAINTIFFS' EX PARTE APPLICATIONS FOR TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW CAUSE REGARDING PRELIMINARY INJUNCTION [ECF NOS. 38, 45]
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Tue Jul 15, 2025 9:54 pm

Supreme Court GOES OFF THE RAILS With New Ruling On Trump’s SCHEME
Katie Phang
Jul 15, 2025

“I respectfully dissent.” SCOTUS destroys America with yet another horrible decision, this one involving the Department of Education. Katie Phang breaks down Justice Sonia Sotomayor’s scathing dissent and explains why Congress needs to find its spine.



Transcript

Yet another abomination of a decision
from the United States Supreme Court.
This one coming in late yesterday.
dealing with Linda McMahon, Secretary
of Education and the Trump
administration.
The reduction in force the RAF that
McMahon instituted at the Department
of Education, as well as Trump's
executive order. And it's just so
disappointing. This is yet another
emergency application. We've talked
about it a lot here at the Katy Fang
News Channel. We've talked about how
it's absurd that the Trump
administration has found this new way of
using this shadow docket to its
advantage to be able to obtain relief
that it otherwise is not getting at the
trial court and the appellate court
levels because it's just wrong. Like
it's just wrong on the law. And as I've
made the comparison, it's like a little
boy running to hide behind mommy's
skirts. It's exactly what this
administration does when it goes to run
behind the Scotas uber conservative
majority of six. And now they've given
once again the Trump administration a
pass to be able to do horrific things to
our American workforce. And because it's
coming from the Supreme Court, it gives
this impression of credibility.
Um because
it's the court of of of the end, right?
There's nothing beyond the United States
Supreme Court. So, let's dive deep into
this decision of which 19 pages of it is
the descent by Justice Sonia Sotomayor.
And it's so worth it to walk it through
with you guys because
one, there is zero
explanation provided by the majority.
So, um I talked about this with Leah
Litman on her fantastic podcast, Strict
Scrutiny. Kate Shaw, Melissa Murray,
Leah Litman. Um because it's the summer,
I I went over and I had the privilege of
co-hosting with Leah last week. And if
you'll go back and I urge you to go and
listen to our our our episode, but Lee
and I talk about the fact that the
laboring or the work is being done by
the trial courts. And in this particular
instance, we're going to get into in a
minute, not only was it the trial court,
but the appella courts actually were
doing work, too. But when you have these
emergency applications and then you get
these these rulings where literally the
majority opinion is just this. I hope
you can see this. It's just this out of
19 pages. And when you're not provided
with a road map or an explanation that
explains why the majority decided the
way it did, then it provides zero
benefit to the lower courts because then
you're left to wonder why the court
ruled the way it did. I mean, you and I
know the answer, right? They ruled the
way that they did because they are
clearly not immune to the to the cult of
personality, which is Donald Trump. But
that's why it's worth it to walk through
the descent because once again, the
dissent being either Katanji Brown
Jackson, Sonia Soayor, Elena Kagan,
these justices are actually having to
explain the law. They're explaining why
the majority gets it wrong, but then
they're explaining the law because, god
forbid, the law actually gets explained
to the American people so they
understand why thousands of people have
now lost their jobs, why thousands of
migrants are now being kidnapped um and
and shipped off of United States soil. I
could go on with the travesty. So, let's
walk through this together um and and
buckle up. School is in session. Let's
go back to law school. So the majority
is this one paragraph and it basically
says that the preliminary injunction
that was entered by a federal judge in
the district court of the district of
Massachusetts
that injunction is stayed meaning it is
put on the back burner. It is put on
chill. It's put on ice. It's not going
and not immigration customs enforcement.
It has no enforcement right now. while
the pending appeal in the first circuit
of the original judge's decision, right,
is is being litigated. And again, as
we've talked about with Supreme Courts,
you have to file a petition for writers
normally to be able to have the Supreme
Court take the case. Um, unless you're
the Trump administration, you do one of
these ridiculous number of emergency
applications.
Should be denied, then the stay, meaning
the block against this judge's
nationwide injunction, will terminate
automatically. But if cert is granted,
meaning the Supreme Court takes this
case after it's gotten its disposition
on the First Circuit Court of Appeals,
then the block on this judge's order
will terminate upon the sending down of
a judgment from the Supreme Court.
That's all it says. It basically
reiterates procedure. Thank you, Scotas
majority. We got it. We've seen so many
of these now that you don't have to go
to law school to understand what is
happening procedurally here, but that's
all they do. So, Justice Sotoayor, she
kicks it into overdrive. And thank thank
God for the rule of law and justice with
Justice Sotoayor. So, let's get into
this. Justice Sotomayor, with whom Kagan
and Jax join, writes straight out of the
gate the following. This case arises out
of the president's unilateral efforts to
eliminate a cabinet level agency
established by Congress nearly half a
century ago. The Department of
Education, as Congress mandated, the
Department plays a vital role in this
nation's education system, safeguarding
equal access to learning and channeling
billions of dollars to schools and
students across the country each year.
Only Congress has the power to abolish
the department. The executive's task, by
contrast, is to quote take care that the
laws be faithfully executed end quote.
Soayor making it clear that there is a
true separation of powers. Congress can
can abolish a department that was
congressionally created. The president's
task is what? As the executive to take
care that the laws are faithfully
executed. Separation of powers. Okay?
And again, this is worth reading in its
entirety to you because there is so much
impact from Justice Sotomayer's words.
quote, "When the executive publicly
announces its intent to break the law
and then executes on that promise, it is
the judiciary's duty to check that
lawlessness, not expedite it." Two lower
courts rose to the occasion,
preliminarily enjoining the mass firings
while the litigation remains ongoing.
Rather than maintain the status quo,
however, this court now intervenes,
lifting the injunction and permitting
the government to proceed with
dismantling the department. That
decision is indefensible. It hands the
executive the power to repeal statutes
by firing all those necessary to carry
them out. The majority is either
willfully blind to the implications of
its ruling or naive. But either way, the
threat to our Constitution's separation
of powers is grave. Unable to join in
this misuse of our emergency docket, I
respectfully descent. kind of surprised
soayor used the adverb respectfully
because she's getting to the point where
she's just basically saying, "I give you
the middle finger with no respect." So,
let's take one second to backtrack and
just talk about this. So, the Trump
administration basically fired 1,400
employees in the Department of
Education. The Trump administration made
it clear that it's going to dismantle
the Department of Education. It has done
so explicitly. It has said so. Linda
McMahon has done it. Donald Trump has
done it. There's no secrets there,
right? So what happened was there were a
group of 19 states that were led by
excuse me 19 states that were led by New
York as well as the District of
Columbia, two public school districts
and and teachers unions and they sued in
federal court in Massachusetts saying
that those reduction enforce the riffs
violated both the constitution and the
federal laws governing administrative
agencies. So a district court judge
enters a nationwide preliminary
injunction saying you cannot do this
reduction in force. You have to bring
back any employees that were terminated
as a result of that riff. And you cannot
take things like student loans and other
parts of the Department of Education and
move them to other federal agencies.
Then that was appealed to the first
circuit and the first circuit said, you
know what, we're not touching that
district court judge's preliminary
injunction. We're going to leave it in
place. And so on June 6th, the Trump
administration ran to Mommy at the
Supreme Court and did an emergency
application asking the justices to put
that district court judges preliminary
injunction on hold. And this is what
ended up happening. And that's what we
got. All righty. So, S Soayora goes on
to say,
"Congress,
Congress told the Department of
Education and gave the Department of
Education as a federal agency the
ability to do many things that benefit
us as Americans. They administer a broad
range of educational programs at the
Department of Education. For example,
the department runs the federal student
financial aid system.
The department's office of civil rights
enforces several anti-discrimination
laws as to federally funded educational
programs. The department additionally
administers the individuals with
disabilities education act which funds
and supports special education services
for more than 7 million students with
disabilities.
Tens of millions of lowincome families
rely on financial assistance programs
administered by the department under
title one. Put simply, schools and
students in every state rely on federal
programs established by Congress and run
by the department established by
Congress. Keep that forefront in your
mind. Congress, what Congress creates,
only Congress can take away. Remember
that rule.
She goes on in the opinion to say the
following in the descent.
About a week into her tenure, Linda
McMahon announced a reduction in force
that would eliminate nearly 50% of the
department's workforce, slashing the
number of employees from 4,133
to 2,183.
In statements to the press, McMahon
confirmed the reduction was quote the
first step on the road to a total
shutdown of the department as directed
by the president. On March 20th of this
year, Trump formalized his directive to
shutter the department by signing
executive order number 14242.
So let's get into the actual procedure.
Let's talk about how the sausage is
made. So get to to so to get to the
preliminary injunction stage, evidence
has to be presented by the plaintiffs in
this case and the defense, the
department Linda McMahon. They also can
and should be presenting evidence. And
during the course of the hearing, this
judge, the trial court judge, this
federal district court judge takes
testimony, reads affidavit, considers
all the evidence, determines the
credibility of the people that are
providing this information, and then
comes to his or her ruling. And in this
case, this judge did exactly that.
The plaintiffs, the school unions, um
the states, the teachers, etc., they
presented all this evidence to the
judge. Soayor makes it clear the
government submitted no evidence to
rebut the factual record that was
compiled by the plaintiffs. Nor did it
argue that the executive could
single-handedly abolish the department.
Instead, it asserted that the mass
termination fell within the president's
authority because it was simply part of
an effort to quote streamline the
department.
The district court granted the
preliminary injunction motion. The court
found that the record abundantly reveals
that the defendant's true intention is
to effectively dismantle the department
without an authorizing statute and that
the terminations would prevent the
department from carrying out its
statutory functions. That unilateral
executive action the district court
concluded likely violated the separation
of powers and the take care clause.
Period. Stop. Let's talk. So if you have
something called a record, which is the
official kind of body of evidence that
can be considered by the trial court and
by an appela court, and if the trial
court judge is the person who is best
situated to determine the true
intentions of the parties, to evaluate
the credibility of the parties, to weigh
the evidence that has been admissible
and has been entered into this case,
then why not show the difference to the
trial court that it is due. In fact, the
law requires requires that you show
deference to the trial court. And in
this instance, the Supreme Court said
whatever trial court and in this
instance, whatever appeals court, we
know better than you. Although not
giving an explanation as to why they
know better.
Let's move quickly on.
The district court stopped the
government from being able to carry out
its directives, the executive order and
the transfer order, meaning the transfer
of those student loans to another agency
and the reduction in force, etc. It
ordered the Department of Education to
reinstate those federal employees to
restore the department to the status
quo. The first circuit court of appeals
denied the government's request to stop
that preliminary injunction from moving
forward. The government, according to
the first circuit, concluded that it did
not even attempt the government did not
even attempt to engage the district
court's record-based findings about the
extent of the reduction in force, the
intent behind both it and the transfer
of functions, or the disabling impact of
those actions. The first circuit noted
that the plaintiffs faced serious
irreparable harms for the department's
inability to provide its statutory
mandated services. And this is where
Sodomayor turns on the burn. rebuffed
twice below. The government now tries
its hand at seeking emerent relief from
this court. Granting such relief is a
matter of this court's discretion which
we have previously exercised only under
extraordinary circumstances. End quote.
So Sodtoayor is reminding her colleagues
on the bench. Emergency relief by way of
the shadow docket emergency
applications. It's supposed to be given
sparingly and it's only supposed to be
done in quote extraordinary
circumstances. It's certainly not
supposed to be done when a trial court
and an appela court has said that that
preliminary injunction is not only
kosher but is necessary to prevent
irreparable harm.
An applicant for emergency relief bears
an especially heavy burden to justify
our intervention. Whereas here the
matter remains pending before the court
of appeals and two lower courts have
already denied that interimm relief. All
true. Soayor reminds the majority that
the law stands as follows. The president
lacks unilateral authority to close a
cabinet level agency. Congress created
the department and only Congress can
abolish it. Rather than contest these
bedrock legal principles, the government
below contends that the mass
terminations were not part of any
planned closure, but are just to cut
bureaucratic bloat. The record
unambiguously refutes the government's
account. The record evidence
credited by the district court and
unrebuted by the government leads to one
conclusion. The executive has seized for
itself the power to repeal federal law
by way of mass terminations in direct
contravention of the take care clause
and our constitution separation of
powers.
And we're just going to kind of fast
forward. Um I urge you to read the
entirety of this opinion because it's
well worth reading. And let's just get
to the very end the last paragraph.
Soayor's descent where she says the
president must take care that the laws
are faithfully executed not set out to
dismantle them. That basic rule
undergurs our constitution separation of
powers. Yet today the majority rewards
clear defiance of that core principle
with emergency relief. Because I cannot
condone such abuse of our equitable
authority, I respectfully descent
again. Um I I will link uh this opinion
because it's worth it for you all to
take the time to read it. And it's
amazing because Soayor writes in a way
that we can all understand. We don't
have to be lawyers to understand.
I want to just take a minute to kind of
just conclude with the following.
It's the Department of Education people.
It is such an important federal agency.
It was such an insult and slap to the
face of Americans when Trump put Linda
freaking McMahon in charge of that
department to begin with. I mean, what
an absolute disc to the value of
education. But then when Trump made it
clear that he wanted to dismantle the
Department of Education, I mean, look, I
get it. He's about as ill-educated as
they come. But that doesn't mean that
the rest of us have to live in ignorance
and have to suffer because Trump doesn't
value education. Trump values loyalty.
That's the only reason why McMahon got
her job. But what an uphill battle that
Soayor, Katandra Brown Jackson, and
Elena KGA have to fight. To have to push
back and to remind their colleagues that
the separation of powers is something
that is supposed to be undisturbed. It
is distinctly within our United States
Constitution. And yet, even though you
have two separate courts, trial court
and appellet court, that have said there
is nothing wrong and that in fact this
preliminary injunction is necessary to
protect the plaintiffs from harm that
cannot be repaired. The Supreme Court
thinks in its arrogance in terms of the
majority, excuse me, the majority thinks
in its arrogance that it knows better.
If there was ever a call for the need to
reform the United States Supreme Court,
I don't know what sounds more clearly
than this. The Supreme Court is
unchecked. It is now ruling as if it is
its own kingdom or FFT of kings and
queens. It needs to be stopped. The
Supreme Court needs to be stopped.
The Democrats need to figure out a way
of reforming that judiciary because it
is doing no one any favors. And the
funny thing is Republicans also are
getting fired in these reductions in
force, right? It's not just Democrats.
So what are you going to do Republicans
when you are falling victim to this
reduction in force either the Department
of Education or somewhere else and then
the big bill bill
comes and bites you in the ass even more
because you don't get the coverage you
need. you don't get the benefits you
need. You don't have the health
insurance you have you need. I mean,
it's a really ugly cycle, isn't it? But
welcome to the reality. Welcome to the
find out part of the uh FA, right? Be
mad, be outraged, demand accountability.
Um, take the time to go read this
opinion. It's worthwhile reading as are
all of the descents at this point
really, but it is such a great walking
through of the law and why the law
matters and why it's important that
Congress grows a pair and actually does
its job as well. I'll see you on the
other side. Katie Fang here. We launched
the Katy Fang News Channel in
partnership with the Midas Touch Network
so we could bring you the latest in
legal and political news. Straight, no
chaser. So, if you're a fellow trutht
teller, hit that subscribe button and
share the word about this channel so we
can build a highinformation America
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Re: Anti-Anti-Nazi Barbarian Hordes are Knocking Down the Ga

Postby admin » Wed Jul 16, 2025 4:15 am

UPDATE: Justice Department issues decision in Epstein case
Brian Tyler Cohen
Jul 15, 2025 Brian Tyler Cohen
Legal Breakdown episode 558: ‪@GlennKirschner2‬ discusses the DOJ's decision on the Maxwell case.

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