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Order Denying Emergency

Date
2023-07-25

Summary

An Order Denying Emergency Motion for Stay Pending Appeal in East Bay Sanctuary Covenant, et al. v. Joseph R. Biden, et al., Case No. 18-cv-06810-JST, in the U.S. District Court for the Northern District of California, signed by United States District Judge Jon S. Tigar and filed August 1, 2023 as Document 195. The order recounts that on July 25, 2023 the Court vacated and remanded the Circumvention of Lawful Pathways rule, 88 Fed. Reg. 31314, and stayed that order for fourteen days. Applying the four stay factors from Nken v. Holder, it concludes that Defendants have not made a strong showing of likely success on the merits. It finds the asserted foreign policy and border management harms speculative or not irreparable, and holds that harm to asylum seekers and the public interest do not favor a stay. The motion is denied and the 14 day stay remains in effect.

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                                            Case 4:18-cv-06810-JST Document 195 Filed 08/01/23 Page 1 of 5




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                                   4                                     UNITED STATES DISTRICT COURT

                                   5                                    NORTHERN DISTRICT OF CALIFORNIA

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                                   7        EAST BAY SANCTUARY COVENANT,                      Case No. 18-cv-06810-JST
                                            et al.,
                                   8                      Plaintiffs,                         ORDER DENYING EMERGENCY
                                   9                                                          MOTION FOR STAY PENDING
                                                   v.                                         APPEAL
                                  10
                                            JOSEPH R. BIDEN, et al.,                          Re: ECF No. 190
                                  11                      Defendants.
                                  12


 United States District Court
                                  13            On July 25, 2023, the Court vacated and remanded Circumvention of Lawful Pathways

                                  14   (“the Rule”), 88 Fed. Reg. 31314 (May 16, 2023), a final rule promulgated by the Department of

                                  15   Justice and the Department of Homeland Security. ECF No. 187. The Court held that the Rule



Northern District of California
                                  16   violates the Administrative Procedure Act (“APA”) because it is contrary to law, is arbitrary and

                                  17   capricious, and was promulgated without adequate opportunity for public comment. Id. Upon

                                  18   Defendants’ unopposed request, the Court stayed its order for fourteen days. Id. at 35.

                                  19            Defendants now seek to stay the Court’s order pending appeal. ECF No. 190. Because

                                  20   Defendants have not met their burden to demonstrate that such a stay is warranted, the Court will

                                  21   deny the motion.

                                  22   I.       LEGAL STANDARD

                                  23            The issuance of a stay is a matter of judicial discretion, not a matter of right, and the “party

                                  24   requesting a stay bears the burden of showing that the circumstances justify an exercise of that

                                  25   discretion.” Nken v. Holder, 556 U.S. 418, 433-34 (2009). In exercising its discretion, the Court

                                  26   must consider: “(1) whether the stay applicant has made a strong showing that he is likely to

                                  27   succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3)

                                  28   whether issuance of the stay will substantially injure the other parties interested in the proceeding;
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                                   1   and (4) where the public interest lies.” Id. at 434 (quoting Hilton v. Braunskill, 481 U.S. 770, 776

                                   2   (1987)).

                                   3   II.      DISCUSSION

                                   4            A.     Likelihood of Success on the Merits

                                   5            “The first factor, likelihood of success on the merits, is the most important.” Mi Familia

                                   6   Vota v. Hobbs, 977 F.3d 948, 952 (9th Cir. 2020). In their motion for stay, Defendants do not

                                   7   articulate on what basis they believe they are likely to succeed on the merits of their appeal. ECF

                                   8   No. 190 at 7. Defendants simply state that, “as [they] explained in their briefing and at argument,

                                   9   the Rule is consistent with the asylum statute, is not arbitrary and capricious, and satisfies all

                                  10   applicable procedural requirements.” Id. For the reasons articulated in the Court’s order granting

                                  11   summary judgment to Plaintiffs, however, the Court concludes that Defendants have not made a

                                  12   strong showing that they are likely to succeed or shown a substantial case for relief on the merits.


 United States District Court
                                  13            B.     Remaining Factors

                                  14            The remaining factors neither weigh strongly in Defendants’ favor nor overcome the first

                                  15   factor. See Al Otro Lado v. Wolf, 952 F.3d 999, 1010 (9th Cir. 2020) (“Only ‘a stronger showing



Northern District of California
                                  16   of one element may offset a weaker showing of another.’”) (quoting All. for the Wild Rockies v.

                                  17   Cottrell, 632 F.3d 1127, 1131 (9th Cir. 2011)); E. Bay Sanctuary Covenant v. Barr, 934 F.3d

                                  18   1026, 1028 (9th Cir. 2019) (denying motion to stay pending appeal, based solely on failure to

                                  19   make a strong showing of likelihood of success on the merits). Because Defendants discuss the

                                  20   remaining factors together, the Court does the same here.

                                  21            To be granted a stay, Defendants must show, at minimum, that “irreparable injury is likely

                                  22   to occur during the period before the appeal is likely to be decided.” Al Otro Lado, 952 F.3d at

                                  23   1007. Defendants argue that the Court’s order will irreparably harm the Government’s foreign

                                  24   policy interests, namely “efforts with Mexico and other countries to address irregular migration,”

                                  25   ECF No. 190 at 4, because the Rule is “necessary to securing continued foreign Government

                                  26   cooperation with the United States’ foreign policy goals,” id. at 6. Specifically, Defendants offer

                                  27   evidence indicating that vacatur “could potentially put . . . in jeopardy” Mexico’s agreement to

                                  28   accept the return or removal of non-Mexican nationals under Title 8, ECF No. 176-2 ¶ 44; that
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                                   1   other countries “may take the view” that the U.S. is no longer committed to addressing irregular

                                   2   migration on a regional basis, id. ¶ 45, and that other countries “could be less inclined to support

                                   3   U.S. efforts to manage migratory flows,” id. ¶ 46. These assertions, which are speculative, are not

                                   4   sufficient to establish that irreparable harm is likely to occur before the appeal is decided.

                                   5          Defendants also argue that the Court’s order will irreparably harm the Government’s

                                   6   border management interests. Id. at 4. The Rule imposes a presumption of asylum ineligibility;

                                   7   likely as a result of this and other concurrent policy changes, the number of individuals

                                   8   encountered attempting to cross the border without authorization each day has dropped. Without

                                   9   the deterrent effect of the Rule, DHS predicts that encounter numbers could rise rapidly, straining

                                  10   DHS’ enforcement operations. ECF No. 176-2 ¶¶ 28-37 (describing increased staffing and

                                  11   transportation costs, diversion of resources from other missions, and downstream economic costs).

                                  12   But these eventualities, if they occur, do not constitute irreparable harm; “[m]ere injuries, however


 United States District Court
                                  13   substantial, in terms of money, time and energy necessarily expended . . . are not enough.” Al

                                  14   Otro Lado, 952 F.3d at 1008 (quoting Sampson v. Murray, 415 U.S. 61, 90 (1974)). The Court

                                  15   assumes for purposes of this order that some increase in the number of encounters is likely to



Northern District of California
                                  16   occur when the Rule is vacated, but is not persuaded that any resulting injury to Defendants is

                                  17   irreparable.

                                  18          Defendants also suggest the Court’s order impermissibly intrudes on the Executive’s

                                  19   interests in foreign affairs and border management, causing a different form of injury. While the

                                  20   Court is mindful of the Executive’s unique role in the conduct of foreign policy, “[o]ur precedents,

                                  21   old and new, make clear that concerns of national security and foreign relations do not warrant

                                  22   abdication of the judicial role.” Holder v. Humanitarian Law Project, 561 U.S. 1, 34 (2010). And

                                  23   while “[t]he [G]overnment’s interest in efficient administration of the immigration laws at the

                                  24   border is . . . weighty,” “control over matters of immigration is a sovereign prerogative, largely

                                  25   within the control of the executive and the legislature.” Landon v. Plasencia, 459 U.S. 21, 34

                                  26   (1982) (emphasis added) ; see Fiallo v. Bell, 430 U.S. 787, 792 (1977) (“[O]ver no conceivable

                                  27   subject is the legislative power of Congress more complete than it is over the admission of

                                  28   [noncitizens].”). Here, Congress has expressly provided that certain noncitizens may apply for
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                                   1   asylum and has constrained the agencies’ discretion to impose additional conditions or limitations

                                   2   on asylum eligibility. Judicial review of such conditions to ensure fidelity to the express will of

                                   3   Congress is an appropriate exercise of judicial authority. And the Court notes that vacating the

                                   4   Rule does not affect the agencies’ discretion to deny any or all individual applications for

                                   5   asylum—Congress vested the agencies with that broad discretion by statute. Congress’ grant of

                                   6   authority to promulgate additional conditions and limitations on asylum eligibility, however, was

                                   7   circumscribed. The Executive Branch retains the full extent of the lawful tools it has available to

                                   8   address irregular migration and manage the border.

                                   9          Further, issuance of a stay will injure other parties interested in this proceeding. While

                                  10   Defendants suggest the Court may only consider harm to Plaintiffs, the Court must consider

                                  11   “whether issuance of the stay will substantially injure the other parties interested in the

                                  12   proceeding,” not simply the parties to this proceeding. Nken, 556 U.S. at 434; see Latta v. Otter,


 United States District Court
                                  13   771 F.3d 496, 500 (9th Cir. 2014). As described in the Court’s order, the Rule exposes asylum

                                  14   seekers to serious risk of violence and will result in some number of asylum seekers with

                                  15   otherwise meritorious claims being denied access to an important protection. Those deemed



Northern District of California
                                  16   ineligible for asylum who cannot meet the higher evidentiary burden required for other forms of

                                  17   protection will be deported to countries where they are at risk of further violence.

                                  18          The public interest factor also does not favor a stay. As Defendants note, there is a “wide

                                  19   public interest in effective measures to prevent the [unauthorized] entry of [noncitizens] at the

                                  20   Mexican border.” United States v. Cortez, 449 U.S. 411, 421 n.4 (1981)). “But the public also

                                  21   has an interest in ensuring that ‘statutes enacted by [their] representatives’ are not imperiled by

                                  22   executive fiat.’” Al Otro Lado, 952 F.3d at 1015 (quoting E. Bay Sanctuary Covenant v. Trump,

                                  23   932 F.3d 742, 779 (9th Cir. 2018)). And “[t]here is generally no public interest in the perpetuation

                                  24   of unlawful agency action.” League of Women Voters of U.S. v. Newby, 838 F.3d 1, 12 (D.C. Cir.

                                  25   2016). “[W]here the agency’s discretion has been clearly constrained by Congress[,] [t]he public

                                  26   interest surely does not cut in favor of permitting an agency to fail to comply with a statutory

                                  27   mandate.” Ramirez v. Immigr. & Customs Enf’t, 310 F. Supp. 3d 7, 33 (D.D.C. 2018).

                                  28   ///
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                                   1                                            CONCLUSION

                                   2          Weighing these factors, the Court concludes that a further stay pending appeal is not

                                   3   warranted here. Defendants’ emergency motion for stay pending appeal is therefore denied. The

                                   4   Court’s previously-issued 14 day stay remains in effect.

                                   5          IT IS SO ORDERED.

                                   6   Dated: August 1, 2023
                                                                                      ______________________________________
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                                                                                                    JON S. TIGAR
                                   8                                                          United States District Judge

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