Memo in Support of Emergency Motion to Restore Nationwide Injunction — East Bay Sanctuary v. Barr (N.D. Cal.)

Record facts

U.S. District Court for the Northern District of California · No. 3:19-cv-04073-JST · Doc. 57-1 · 2019-08-19 · Docket on CourtListener

Full text

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Katrina Eiland (SBN 275701) 
Cody Wofsy (SBN 294179) 
Spencer Amdur (SBN 320069) 
Julie Veroff (SBN 310161) 
ACLU FOUNDATION  
IMMIGRANTS’ RIGHTS PROJECT 
39 Drumm Street 
San Francisco, CA 94111 
T: (415) 343-0770 
F: (415) 395-0950 
keiland@aclu.org 
cwofsy@aclu.org  
samdur@aclu.org 
jveroff@aclu.org  
 
Lee Gelernt* 
Omar C. Jadwat* 
Anand Balakrishnan* 
ACLU FOUNDATION 
IMMIGRANTS’ RIGHTS PROJECT 
125 Broad Street, 18th Floor 
New York, NY 10004 
T: (212) 549-2660 
F: (212) 549-2654 
lgelernt@aclu.org 
ojadwat@aclu.org 
abalakrishnan@aclu.org 
Attorneys for Plaintiffs  
(Additional counsel listed on following page)   
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
 
East Bay Sanctuary Covenant; Al Otro Lado; 
Innovation Law Lab; and Central American 
Resource Center in Los Angeles, 
 
Plaintiffs, 
 
v. 
 
William Barr, Attorney General, in his official 
capacity; U.S. Department of Justice; James 
McHenry, Director of the Executive Office for 
Immigration Review, in his official capacity; the 
Executive Office for Immigration Review; Kevin 
McAleenan, Acting Secretary of Homeland 
Security, in his official capacity; U.S. Department 
of Homeland Security; Ken Cuccinelli, Acting 
Director of the U.S. Citizenship and Immigration 
Services, in his official capacity; U.S. Citizenship 
and Immigration Services; John Sanders, 
Commissioner of U.S. Customs and Border 
Protection, in his official capacity; U.S. Customs 
and Border Protection; Matthew Albence, Acting 
Director of Immigration and Customs 
Enforcement, in his official capacity; Immigration 
and Customs Enforcement, 
 
Defendants. 
 
 
Case No.: 3:19-cv-04073-JST 
 
MEMORANDUM IN SUPPORT OF 
PLAINTIFFS’ EMERGENCY 
MOTION TO CONSIDER 
SUPPLEMENTAL EVIDENCE AND 
RESTORE THE NATIONWIDE 
SCOPE OF THE INJUNCTION  
  
 
Case 3:19-cv-04073-JST   Document 57-1   Filed 08/19/19   Page 1 of 10

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Melissa Crow** 
SOUTHERN POVERTY LAW CENTER 
1101 17th Street, NW Suite 705 
Washington, D.C. 20036 
T: (202) 355-4471 
F: (404) 221-5857 
melissa.crow@splcenter.org 
 
Mary Bauer** 
SOUTHERN POVERTY LAW CENTER 
1000 Preston Avenue 
Charlottesville, VA  22903 
T:  (470) 606-9307 
F:  (404) 221-5857 
mary.bauer@splcenter.org 
 
 
 
 
 
 
 
Attorneys for Plaintiffs 
 
*Admitted Pro hac vice  
**Pro hac vice application forthcoming 
 
 
Baher Azmy** 
Angelo Guisado** 
Ghita Schwarz** 
CENTER FOR CONSTITUTIONAL RIGHTS 
666 Broadway, 7th Floor 
New York, NY 10012 
T: (212) 614-6464 
F: (212) 614-6499 
bazmy@ccrjustice.org 
aguisado@ccrjustice.org 
gschwarz@ccrjustice.org 
 
Christine P. Sun (SBN 218701) 
Vasudha Talla (SBN 316219) 
Angélica Salceda (SBN 296152) 
AMERICAN CIVIL LIBERTIES UNION 
FOUNDATION OF NORTHERN 
CALIFORNIA, INC. 
39 Drumm Street 
San Francisco, CA 94111 
T: (415) 621-2493 
F: (415) 255-8437 
csun@aclunc.org 
vtalla@aclunc.org 
asalceda@aclunc.org 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
INTRODUCTION 
 
This Court issued an order preliminarily enjoining the challenged Interim Final Rule 
nationwide on July 24, 2019.  See ECF No. 42.  The government sought an administrative stay and a 
stay pending appeal from the Ninth Circuit.  See No. 19-16487 (9th Cir.), Dkt. 3-1.  The Ninth 
Circuit motions panel denied the government’s request for an administrative stay that same day.  See 
id., Dkt. 19.  On August 16, 2019, the motions panel denied the government’s request for a stay 
“insofar as the injunction applies within the Ninth Circuit.”  Id., Dkt. 30 (Order) at 3.   
The motions panel did not disturb this Court’s conclusions about Plaintiffs’ likelihood of 
success on the merits or the equities, and agreed that the government has “not made the required 
‘strong showing’ that they are likely to succeed on the merits on [the notice-and-comment] issue.”  
Id.  However, the motions panel limited the scope of the injunction to the Ninth Circuit.  Id.  
Critically, however, the panel recognized that a nationwide injunction of the Rule could well be 
appropriate.  But before it would uphold nationwide relief in this case, the panel required further 
record evidence and findings by this Court connecting that scope of relief to Plaintiffs’ injuries.  Id. 
at 3-6. Accordingly, the motions panel provided that “[w]hile [the preliminary injunction] appeal 
proceeds, the district court retains jurisdiction to further develop the record in support of a 
preliminary injunction extending beyond the Ninth Circuit.”  Id. at 8-9. 
Consistent with that express permission from the Ninth Circuit, Plaintiffs now respectfully 
request that the Court consider additional evidence in support of a nationwide injunction, and, based 
on supplemental findings of fact, restore the nationwide scope of the preliminary injunction.1  
Absent nationwide relief, the serious and irreparable harm to Plaintiffs caused by the Rule cannot be 
fully remedied.   
                                                 
1 Given the panel’s clear acknowledgment that this Court retains jurisdiction to revisit the 
proper scope of the injunction, there is no jurisdictional bar to this Court restoring the nationwide 
scope of the preliminary injunction based on further factual findings.  See Order at 8-9; id. at 9 
(“Because the record is insufficiently developed as to the question of the national scope of the 
injunction, we vacate the injunction to the extent that it applies outside California and remand to the 
district court for a more searching inquiry into whether this case justifies the breadth of the 
injunction imposed.”) (quoting City & County of San Francisco v. Trump, 897 F.3d 1225, 1245 (9th 
Cir. 2018)); see also Fed. R. Civ. Proc. 62(d) (permitting district courts to “modify, restore, or grant 
an injunction” even while an interlocutory appeal is pending). 
 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
ARGUMENT 
I. 
Nationwide Relief Is Necessary to Remedy Plaintiffs’ Injuries. 
As the Ninth Circuit motions panel confirmed, nationwide injunctions will be upheld where 
they are “necessary to remedy a plaintiff’s harm.”  Order at 4.  The declarations accompanying this 
motion—which supplement the declarations filed by Plaintiffs in support of their motion for a 
temporary restraining order, see ECF No. 3-2, 3-3, 3-4, 3-5—clearly demonstrate that the injunction 
in this case must be nationwide “to remedy the specific harm shown” to Plaintiffs.  Order at 4 
(quoting City and County of San Francisco v. Trump, 897 F.3d 1225, 1243-45 (9th Cir. 2018)).  
As set forth below, Plaintiffs have specific reasons why a nationwide injunction is necessary 
to remedy the harms to their organizations.  But one common theme is that asylum seekers 
frequently do not enter the country and complete their asylum proceedings within the same circuit, 
and it is not possible to predict asylum seekers’ movements in advance.  For instance, an asylum 
seeker may enter the U.S. through Texas, have a credible fear interview in New Jersey, and 
ultimately apply for asylum in California.  See Alvarez Decl. ¶ 6; Supp. Manning Decl. ¶¶ 12, 16.  
The Declaration of Aaron Reichlin-Melnick discusses the reasons for and frequency with which this 
movement occurs.  The declarations from each of the four Plaintiffs discuss these scenarios as they 
relate to the organization’s work.   
Innovation Law Lab: Law Lab’s operations are not limited to the Ninth Circuit.  In addition 
to its work in the Ninth Circuit, Law Lab has offices in Georgia, Missouri, and Texas; operates pro 
bono representation projects in Georgia, Kansas, Missouri, and North Carolina, with expansion 
underway to New Mexico; and provides direct representation to persons applying for asylum outside 
the Ninth Circuit.  See Supp. Manning Decl. ¶¶ 4-5.  And six of the seven detention centers at which 
Law Lab regularly works are outside the Ninth Circuit.  Id. ¶ 19.  Given Law Lab’s national scope, 
an injunction limited to the Ninth Circuit would not fully remedy the harm to the organization. 
First, because Law Lab provides training, materials, and overall legal assistance to other 
organizations and asylum seekers throughout the country, the harm to Law Lab will not be remedied 
by an injunction limited to the Ninth Circuit.  Among other things, Law Lab currently uses 
synchronized templates and materials across its program sites.  A geographically limited injunction 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
will force it to abandon this practice, and will require it to meaningfully restructure its operations to 
effectively serve persons who are subject to the transit ban as well as persons who are not.  Id. ¶¶ 7-
8, 13-14, 20.   
Second, the fact that Law Lab directly represents individuals outside the Ninth Circuit means 
that an injunction limited to the Ninth Circuit is insufficient.  Id. ¶ 15. 
Moreover, providing legal guidance and assistance to persons subject to the Rule will be a 
significant burden on Law Lab employee time and program operations, as these persons will now 
only be eligible for withholding of removal and relief under the Convention Against Torture.  Those 
forms of relief are more time consuming than asylum to pursue, as they involve higher burdens of 
proof than asylum and require the development of distinct and more in-depth legal analyses.  They 
also do not permit derivative applications to be filed on behalf of family members.  In addition, Law 
Lab will have to retrain its volunteers on these forms of relief and adjust how it screens individuals 
for relief.  Id. ¶¶ 9, 11.   
And, importantly, because asylum seekers often move between different locations—and 
between judicial circuits—during their proceedings, Law Lab’s ability to provide legal assistance 
workshops will be hindered.  Id. ¶¶ 12, 16.  For instance, at Law Lab’s workshops in Tijuana for 
individuals about to seek asylum in the U.S., Law Lab will have to provide guidance about a Rule 
that might apply at different points throughout their asylum cases, depending on where they 
ultimately cross the border or where they end up once in the U.S.  Indeed, the number of asylum 
seekers Law Lab serves in Tijuana who end up in detention centers in Louisiana and Mississippi has 
been significantly increasing.  Id. ¶ 12.  See also Reichlin-Melnick Decl. (discussing movement of 
asylum seekers across jurisdictions).2  As a result, it will now be impossible simply to provide all of 
these asylum seekers and their legal representatives with one set of guidelines. 
                                                 
2 The Reichlin-Melnick declaration analyzes recent statistics from the Department of 
Homeland Security (“DHS”) and Executive Office for Immigration Review demonstrating that 
asylum seekers frequently move throughout the country during the asylum process, either by their 
choice or because DHS transfers detained asylum seekers from one detention center to another.  This 
data reveals that there is almost no connection between asylum seekers’ place of entry and ultimate 
destination.  Reichlin-Melnick Decl. ¶¶ 5-6, 14-15. 
 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
Finally, an injunction limited to the Ninth Circuit not only will frustrate Law Lab’s 
operations outside the Ninth Circuit, but will adversely impact its programs within the Ninth Circuit 
as well.  Because serving individuals affected by the Rule’s categorical ban is so time consuming, 
Law Lab will have to direct significant resources towards their representation, which will negatively 
affect clients in the Ninth Circuit and may force Law Lab to serve fewer people overall.  Supp. 
Manning Decl. ¶ 17.  
East Bay Sanctuary Covenant (“EBSC”): The harms caused to EBSC by the Rule, see ECF 
No. 3-2, will persist if the Rule is allowed to go into effect everywhere other than the Ninth Circuit.  
See Supp. Smith Decl. ¶ 4.  Part of EBSC’s mission is to serve clients in affirmative asylum cases, 
regardless of where they entered the United States.  Accordingly, EBSC serves clients who enter the 
United States anywhere in the country, not just the Ninth Circuit.  A sizable portion of EBSC’s 
clients enter the United States outside the Ninth Circuit’s geographic boundaries and then end up in 
California, where they apply for asylum.  More than 22% of EBSC’s affirmative asylum applications 
filed in 2019 were on behalf of clients who transited through Mexico without applying for protection 
there and then entered the United States in Texas or New Mexico, i.e., outside the Ninth Circuit.  If 
the organization is unable to serve a sizable portion of its client base in affirmative asylum cases, its 
mission will be frustrated, and a core part of its operations will be undermined.  Id. ¶¶ 5, 7.  
For the same reason, an injunction limited to the Ninth Circuit also jeopardizes EBSC’s 
funding streams.  Pursuant to a grant from the California Department of Social Services (“CDSS”), 
EBSC receives $2,000 for every affirmative asylum case it files.  If, because of the Rule, EBSC is no 
longer able to handle affirmative asylum cases for individuals who transit through a third country en 
route to the southern border and enter outside the Ninth Circuit, the organization likely will face a 
marked decrease in its budget.  Indeed, if the Rule is allowed to remain in effect outside the Ninth 
Circuit, EBSC estimates that it could lose up to $50,000 under the terms of its CDSS grant during 
the rest of 2019 and up to $100,000 in 2020.  Id. ¶ 8.  
Because of the strain imposed on EBSC if the Rule remains in effect outside of the Ninth 
Circuit, EBSC will either have to significantly cut its affirmative asylum program and staff, or 
overhaul its program to provide types of assistance it is not currently equipped or trained to provide.  
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
Id. ¶ 9.  Notably, EBSC does not currently have sufficient capacity or expertise to handle 
applications for humanitarian relief in the removal context.  Yet to continue serving clients affected 
by the Rule, EBSC will have to shift to representing those individuals in removal cases.  Doing so 
would be extremely resource intensive for EBSC.  Id. ¶ 10.  EBSC will also be burdened by having 
to provide different services to those subject to the Rule and those not subject to the Rule.  Id. ¶¶ 12-
13.  
CARECEN: The injuries inflicted on CARECEN by the Rule, see ECF No. 3-5, will persist 
if the Rule is not enjoined nationwide, see Alvarez Decl. ¶ 4.  CARECEN represents Central 
American asylum seekers regardless of where they enter the United States.  Nearly all of 
CARECEN’s current asylum clients entered through the southern border after transiting through a 
third country without applying for protection there, and at least 60% of those individuals entered 
outside of the Ninth Circuit.  Id. ¶ 5. Thus, the majority of CARECEN’s asylum clients could still be 
subject to the Rule’s categorical bar on asylum under an injunction limited to the Ninth Circuit.  Id.    
CARECEN would be forced to divert significant resources to serve these clients, as they would only 
be eligible for far more resource-intensive forms of relief, such as withholding and CAT protection.  
Id. ¶¶ 8-9.  Despite having to devote significantly increased resources to such applications, 
CARECEN’s main source of funding for its asylum work pays a fixed amount per case.  This will 
significantly strain the organization’s budget.  Id. ¶ 9. 
In addition, CARECEN will have to undertake time consuming screening efforts to 
determine whether a prospective client is subject to the Rule under a geographically limited 
injunction.  Prospective clients who call CARECEN’s offices for representation frequently do not 
have paperwork showing where they entered the country or have other geographical information that 
may be relevant to the applicability of the Rule.  Id. ¶ 11.  CARECEN staff therefore will have to do 
additional investigation and screening to determine whether the Rule is likely to apply.  Id.  It will 
also have to bifurcate its operations to provide different services to those subject to the Rule and 
those not subject to it.  Id. ¶¶ 10-11.  
Al Otro Lado: Al Otro Lado will continue to suffer injuries if the Rule is enjoined only in the 
Ninth Circuit.  See ECF No. 3-3; Ramos Decl. ¶¶ 3-4.  Of the thousands of noncitizens Al Otro Lado 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
serves through its offices in Tijuana, Mexico, not all cross the border in the Ninth Circuit.  Rather, 
some ultimately enter the United States elsewhere, including Texas and New Mexico.  Id. ¶ 5.  It is 
impossible for Al Otro Lado to know with certainty ex ante where a given asylum seeker whom they 
serve will ultimately enter the United States.  Id. ¶¶ 5-8.3   As a result, they will now have to provide 
burdensome additional guidance to ensure that individuals understand the Rule’s impact in different 
parts of the United States.  Id. ¶¶ 9-10. 
Likewise, Al Otro Lado serves individuals who end up outside the Ninth Circuit for their 
asylum proceedings.  Al Otro Lado clients who entered the United States along the southern border 
in California have ended up in Colorado, Georgia, Maine, Maryland, Michigan, Minnesota, and 
Wisconsin.  Id. ¶ 6.  This cross-circuit movement happens because of where the government chooses 
to detain a given asylum seeker, or because of where a given asylum seeker goes to live after release 
from detention.  Id.  See also Reichlin-Melnick Decl.  In Al Otro Lado’s experience, this cross-
circuit movement is quite common, particularly for unaccompanied minors.  Ramos Decl. ¶ 7.  As 
with the uncertainty about ultimate border-crossing locations, it is impossible for Al Otro Lado to 
know for certain where an individual they advise will end up once they are in the United States.  Id. 
¶ 8.  
As a result, if the Rule is only enjoined in certain parts of the country, rather than nationwide, 
Al Otro Lado will have to advise asylum seekers without knowing whether they will ultimately be 
subject to the Rule’s categorical asylum bar or not.  To fulfill their professional obligations, Al Otro 
Lado will have to account for all possibilities in giving advice.  Having to do so will require Al Otro 
Lado to expend significant organizational resources regarding training materials, staff time, and 
capacity, and would create a serious burden for the organization.  Id. ¶¶ 9-10.   
II. 
Nationwide Relief Is Appropriate on the Record Here. 
This Court and the Ninth Circuit concluded that the first asylum ban was likely unlawful and 
enjoined it nationwide.  The Supreme Court did not disturb that conclusion and let stand the 
                                                 
3 Likewise, Law Lab’s declaration makes the same point that the organization does not know 
in advance where asylum seekers it serves in Mexico will enter the U.S. or where they will travel 
around the country during the asylum process.  Supp. Manning Decl. ¶¶ 12, 16. 
 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
injunction’s nationwide scope.  See Trump v. East Bay Sanctuary Covenant, 139 S.Ct. 782 (2018) 
(denying stay).  The record of harm to Plaintiffs absent a nationwide injunction, as supplemented, is 
even stronger than the record in that case.  The Court should therefore reinstate the nationwide 
injunction to remedy Plaintiffs’ injuries.  Moreover, the public interest calculation—which the stay 
panel did not disturb—strongly favors a nationwide injunction given the grave harm individual 
migrants will face. 
CONCLUSION 
 
For the foregoing reasons, Plaintiffs’ motion should be granted.   
 
 
Dated: August 19, 2019 
 
 
Katrina Eiland (SBN 275701) 
Cody Wofsy (SBN 294179) 
Spencer Amdur (SBN 320069) 
Julie Veroff (SBN 310161) 
AMERICAN CIVIL LIBERTIES UNION 
FOUNDATION  
IMMIGRANTS’ RIGHTS PROJECT 
39 Drumm Street 
San Francisco, CA 94111 
T:  (415) 343-1198 
F:  (415) 395-0950 
keiland@aclu.org 
cwofsy@aclu.org 
samdur@aclu.org 
jveroff@aclu.org 
 
Melissa Crow** 
SOUTHERN POVERTY LAW CENTER 
1101 17th Street, NW Suite 705 
Washington, D.C. 20036 
T: (202) 355-4471 
F: (404) 221-5857 
melissa.crow@splcenter.org 
 
 
 
 
 
 
 
Respectfully submitted,  
 
/s/ Lee Gelernt  
Lee Gelernt* 
Omar Jadwat* 
Anand Balakrishnan* 
AMERICAN CIVIL LIBERTIES UNION 
FOUNDATION  
IMMIGRANTS’ RIGHTS PROJECT 
125 Broad St., 18th Floor 
New York, NY 10004 
T:  (212) 549-2660 
F:  (212) 549-2654 
lgelernt@aclu.org 
ojadwat@aclu.org 
abalakrishnan@aclu.org 
 
 
Christine P. Sun (SBN 218701) 
Vasudha Talla (SBN 316219) 
Angélica Salceda (SBN 296152) 
AMERICAN CIVIL LIBERTIES UNION OF 
NORTHERN CALIFORNIA, INC.  
39 Drumm Street 
San Francisco, CA 94111 
T: (415) 621-2493 
F: (415) 255-8437 
csun@aclunc.org 
vtalla@aclunc.org 
asalceda@aclunc.org 
 
 
 
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Memo in Support of Mot. to Supplement the Record and Restore Nationwide Relief 
Case No.: 3:19-cv-04073 
 
Mary Bauer** 
SOUTHERN POVERTY LAW CENTER 
1000 Preston Avenue 
Charlottesville, VA  22903 
T: (470) 606-9307 
F: (404) 221-5857 
mary.bauer@splcenter.org 
 
 
Attorneys for Plaintiffs 
 
 
*Admitted Pro hac vice  
** Pro hac vice application forthcoming 
 
 
 
 
 
 
Baher Azmy** 
Angelo Guisado** 
Ghita Schwarz** 
CENTER FOR CONSTITUTIONAL RIGHTS 
666 Broadway, 7th Floor 
New York, NY 10012 
Telephone: (212) 614-6464 
Facsimile: (212) 614-6499 
bazmy@ccrjustice.org 
aguisado@ccrjustice.org 
gschwarz@ccrjustice.org 
 
 
 
 
 
 
 
 
 
Case 3:19-cv-04073-JST   Document 57-1   Filed 08/19/19   Page 10 of 10

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