Dear IMLA Immigration Working Group:

Here are some additional updates for the group.

1. President Trump indicated yesterday that he is going to suspend all federal funding to sanctuary cities and states beginning on 2/1.  https://www.politico.com/news/2026/01/13/white-house-end-funding-sanctuary-cities-states-00726557.  Please let me know if you hear anything else about this in terms of direct communication to your jurisdiction.

2. San Diego filed suit against the federal government for trespass, public nuisance and other claims in order to halt the federal government's construction of razor wire fencing on City-owned property.  The suit seeks to protect environmentally sensitive land that is part of the City's Multiple Species Conservation Program and ensure compliance with longstanding agreements to preserve critical habitats.  You can read the complaint here: https://files.constantcontact.com/7fef1c1f901/78a97f42-d0ad-4077-94b0-1e3300697e20.pdf?rdr=true

3. The Ninth Circuit vacated the stay in Oregon v. Trump, the National Guard case.  This was after the defendants withdrew their request for a stay pending appeal and after representing that the Oregon National Guard members were in transit to demobilize.  https://cdn.ca9.uscourts.gov/datastore/opinions/2026/01/08/25-6268.pdf

4. LA County has adopted a new ordinance limiting the use of county property from being used for other than county purposes, including for any civil enforcement staging, processing, or operations, including civil immigration enforcement.  You can view it here:  https://file.lacounty.gov/SDSInter/bos/supdocs/211619.pdf

5. I am attaching the lawsuit filed by Minnesota, Minneapolis, & St. Paul against Noem & DHS, as well as the TRO related to the surge in immigration enforcement in those jurisdictions.  The court converted the TRO to a motion for a PI and gave the defendants until 1/19/26 to respond.

The complaint highlights that the President has deployed over 2,000 DHS agents to the Twin Cities in what is being called "Operation Metro Surge" and that this number greatly exceeds the number of sworn police offices Minneapolis and St. Paul have combined.  The complaint alleges that the Defendants' actions are "interfering with the ability of state and local officials to protect and care for their residents."  And the Plaintiffs allege that the Defendants' tactics are endangering the health, safety, and welfare of the Plaintiffs' residents and that it is the state and city governments that will then bear both tangible and intangible costs as a result.

The complaint claims that the agents are engaged in racial profiling, including arresting and detaining US citizens.  It also details that the agents have been driving in unsafe and reckless ways, causing traffic accidents, engaging in warrantless arrests, and changing their license plates on their vehicles.  The complaint also alleges that the federal agents are engaging in actions intended to "spark public outrage," for example, by detaining a woman and dragging her "handcuffed across a frozen road, despite being repeatedly told by bystanders that she was pregnant."  The complaint notes that Minneapolis has received numerous 911 calls related to DHS agents engaging in inappropriate force or threats of force including brandishing guns, pepper spraying, shoving, and using tear gas.

The complaint then explains that the tactics, including aggressive enforcement at sensitive locations, has led to protests and that the defendants have engaged in unlawful conduct toward the protestors and legal observers as well.

In addition to the foregoing, the complaint includes the details of the fatal shooting of Renee Good.  Immigration enforcement activity continued that day after the shooting including at a Minneapolis high school where agents fired pepper spray at individuals in a crowd that included students, teachers, and school administrators. As a result, Minneapolis canceled public schools for two days for 30,000 students.

In terms of the impact on the cities, the complaint explains that Minneapolis has received over eighty 911 calls related to the defendants' actions, which all take time and resources away from other law enforcement functions.  Minneapolis police needed to respond to twenty-four ICE related incidents between 12/9-1/7.  And law enforcement has responded to tense protests which the complaint alleges were caused by the "Defendants' aggressive and reckless actions."  Minneapolis has begun tracking overtime related to its response to the defendants' immigration enforcement activities.  And in just 2 days, between 1/7 - 1/9, the officers had already worked more than 3,000 hours of overtime related to this activity, which is an estimated $2 million cost. Officers time off was also all canceled and they are working longer shifts as a result of this activity.  There are also details about impacts on officers' mental health and well-being.

St. Paul also indicates in the complaint that the defendants' tactics, including failing to identify themselves and wearing masks, are undermining trust in SPPD which in turn will lead to a decrease in reported crimes and cooperation with investigations. St. Paul also details DHS' unlawful commandeering of city-owned parking lots without authorization from the city.

The cities also note that the Defendants' actions have caused a decrease in retail activity, resulting in lower tax revenue.

The allegations are based on violations of

                                                          i.      The Tenth Amendment,

                                                        ii.      Equal Sovereignty Under the Constitution (brought by Minnesota only),

                                                      iii.      The APA related to violation of state law/city ordinances prohibiting individuals from concealing their identity by wearing masks in public & a state law prohibiting the misuse of license plates;

                                                       iv.      The APA as contrary to law for the use of excessive force against the plaintiffs' residents

                                                        v.      the APA by acting contrary to law and engaging in warrantless arrests without individualized assessment of immigration status

                                                       vi.      the APA as contrary to law by conducting border patrol enforcement actions as if the agents are near the border

                                                     vii.      The APA as arbitrary and capricious by revoking the 2021 sensitive locations policy

                                                   viii.      The First Amendment as unlawful retaliation and viewpoint discrimination

In their TRO, they request the Court enter a temporary restraining order to "stop Defendants' conduct causing Plaintiffs harm by: (1) ordering Defendants to cease Operation Metro Surge; and (2) ordering the agents that may lawfully remain in  Minnesota to cease their unlawful conduct, which includes, but is not limited to, prohibiting  racial profiling, the use of excessive force, retaliation, and enforcement at sensitive  locations; requiring that Defendants equip their agents with body-worn cameras; and  requiring that state law and Defendants' own policies be followed."

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Amanda Karras (she/her)
Executive Director / General Counsel
International Municipal Lawyers Association
P: (202) 466-5424 x7116
D: (202) 742-1018
51 Monroe St. Suite 404 Rockville, MD, 20850
Plan Ahead! See IMLA's upcoming eventshttps://imla.org/events/, calls and programming.

Dear IMLA Immigration Working Group:

A couple of additional updates:

1. I have a correction on #4 below.  LA County has not adopted the ordinance yet.  Rather, the council directed its County Counsel to come back with an ordinance limiting the use of county property from being used for other than county purposes, including for any civil enforcement staging, processing, or operations, including civil immigration enforcement.  The motion gives the county counsel 30 days to do so.

2. Also, the Department of Transportation has moved to dismiss its appeal in California v. DOT.  https://storage.courtlistener.com/recap/gov.uscourts.ca1.53717/gov.uscourts.ca1.53717.00108390108.0.pdf

Thanks,
Amanda

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Amanda Karras (she/her)
Executive Director / General Counsel
International Municipal Lawyers Association
P: (202) 466-5424 x7116
D: (202) 742-1018
51 Monroe St. Suite 404 Rockville, MD, 20850
Plan Ahead! See IMLA's upcoming eventshttps://imla.org/events/, calls and programming.

From: Amanda Karras via Immigration immigration@lists.imla.org
Sent: Wednesday, January 14, 2026 3:43 PM
Subject: [Immigration] IMLA Immigration Working Group

Dear IMLA Immigration Working Group:

Here are some additional updates for the group.

1. President Trump indicated yesterday that he is going to suspend all federal funding to sanctuary cities and states beginning on 2/1.  https://www.politico.com/news/2026/01/13/white-house-end-funding-sanctuary-cities-states-00726557https://urldefense.proofpoint.com/v2/url?u=https-3A__www.politico.com_news_2026_01_13_white-2Dhouse-2Dend-2Dfunding-2Dsanctuary-2Dcities-2Dstates-2D00726557&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=SppcCZYKwxjUf_wGMSc7DZgVe-oBaHKN5FFX_HArzew&e=.  Please let me know if you hear anything else about this in terms of direct communication to your jurisdiction.

2. San Diego filed suit against the federal government for trespass, public nuisance and other claims in order to halt the federal government's construction of razor wire fencing on City-owned property.  The suit seeks to protect environmentally sensitive land that is part of the City's Multiple Species Conservation Program and ensure compliance with longstanding agreements to preserve critical habitats.  You can read the complaint here: https://files.constantcontact.com/7fef1c1f901/78a97f42-d0ad-4077-94b0-1e3300697e20.pdf?rdr=truehttps://urldefense.proofpoint.com/v2/url?u=https-3A__files.constantcontact.com_7fef1c1f901_78a97f42-2Dd0ad-2D4077-2D94b0-2D1e3300697e20.pdf-3Frdr-3Dtrue&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=nY090gHuuaT3aWj9Kw-NAHs510kcymcsd6kiHyxviZY&e=

3. The Ninth Circuit vacated the stay in Oregon v. Trump, the National Guard case.  This was after the defendants withdrew their request for a stay pending appeal and after representing that the Oregon National Guard members were in transit to demobilize.  https://cdn.ca9.uscourts.gov/datastore/opinions/2026/01/08/25-6268.pdfhttps://urldefense.proofpoint.com/v2/url?u=https-3A__cdn.ca9.uscourts.gov_datastore_opinions_2026_01_08_25-2D6268.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=uPHgr0zpEcQpEhfvtWXb5Qs_X9K3SNxAUc2jx8C_J7Y&e=

4. LA County has adopted a new ordinance limiting the use of county property from being used for other than county purposes, including for any civil enforcement staging, processing, or operations, including civil immigration enforcement.  You can view it here:  https://file.lacounty.gov/SDSInter/bos/supdocs/211619.pdfhttps://urldefense.proofpoint.com/v2/url?u=https-3A__file.lacounty.gov_SDSInter_bos_supdocs_211619.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=PJPQEOT-tyuKek8bq8X5Gprq5ZEn64IvCmyr1zRoKhw&e=

5. I am attaching the lawsuit filed by Minnesota, Minneapolis, & St. Paul against Noem & DHS, as well as the TRO related to the surge in immigration enforcement in those jurisdictions.  The court converted the TRO to a motion for a PI and gave the defendants until 1/19/26 to respond.

The complaint highlights that the President has deployed over 2,000 DHS agents to the Twin Cities in what is being called "Operation Metro Surge" and that this number greatly exceeds the number of sworn police offices Minneapolis and St. Paul have combined.  The complaint alleges that the Defendants' actions are "interfering with the ability of state and local officials to protect and care for their residents."  And the Plaintiffs allege that the Defendants' tactics are endangering the health, safety, and welfare of the Plaintiffs' residents and that it is the state and city governments that will then bear both tangible and intangible costs as a result.

The complaint claims that the agents are engaged in racial profiling, including arresting and detaining US citizens.  It also details that the agents have been driving in unsafe and reckless ways, causing traffic accidents, engaging in warrantless arrests, and changing their license plates on their vehicles.  The complaint also alleges that the federal agents are engaging in actions intended to "spark public outrage," for example, by detaining a woman and dragging her "handcuffed across a frozen road, despite being repeatedly told by bystanders that she was pregnant."  The complaint notes that Minneapolis has received numerous 911 calls related to DHS agents engaging in inappropriate force or threats of force including brandishing guns, pepper spraying, shoving, and using tear gas.

The complaint then explains that the tactics, including aggressive enforcement at sensitive locations, has led to protests and that the defendants have engaged in unlawful conduct toward the protestors and legal observers as well.

In addition to the foregoing, the complaint includes the details of the fatal shooting of Renee Good.  Immigration enforcement activity continued that day after the shooting including at a Minneapolis high school where agents fired pepper spray at individuals in a crowd that included students, teachers, and school administrators. As a result, Minneapolis canceled public schools for two days for 30,000 students.

In terms of the impact on the cities, the complaint explains that Minneapolis has received over eighty 911 calls related to the defendants' actions, which all take time and resources away from other law enforcement functions.  Minneapolis police needed to respond to twenty-four ICE related incidents between 12/9-1/7.  And law enforcement has responded to tense protests which the complaint alleges were caused by the "Defendants' aggressive and reckless actions."  Minneapolis has begun tracking overtime related to its response to the defendants' immigration enforcement activities.  And in just 2 days, between 1/7 - 1/9, the officers had already worked more than 3,000 hours of overtime related to this activity, which is an estimated $2 million cost. Officers time off was also all canceled and they are working longer shifts as a result of this activity.  There are also details about impacts on officers' mental health and well-being.

St. Paul also indicates in the complaint that the defendants' tactics, including failing to identify themselves and wearing masks, are undermining trust in SPPD which in turn will lead to a decrease in reported crimes and cooperation with investigations. St. Paul also details DHS' unlawful commandeering of city-owned parking lots without authorization from the city.

The cities also note that the Defendants' actions have caused a decrease in retail activity, resulting in lower tax revenue.

The allegations are based on violations of

                                                          i.      The Tenth Amendment,

                                                        ii.      Equal Sovereignty Under the Constitution (brought by Minnesota only),

                                                      iii.      The APA related to violation of state law/city ordinances prohibiting individuals from concealing their identity by wearing masks in public & a state law prohibiting the misuse of license plates;

                                                       iv.      The APA as contrary to law for the use of excessive force against the plaintiffs' residents

                                                        v.      the APA by acting contrary to law and engaging in warrantless arrests without individualized assessment of immigration status

                                                       vi.      the APA as contrary to law by conducting border patrol enforcement actions as if the agents are near the border

                                                     vii.      The APA as arbitrary and capricious by revoking the 2021 sensitive locations policy

                                                   viii.      The First Amendment as unlawful retaliation and viewpoint discrimination

In their TRO, they request the Court enter a temporary restraining order to "stop Defendants' conduct causing Plaintiffs harm by: (1) ordering Defendants to cease Operation Metro Surge; and (2) ordering the agents that may lawfully remain in  Minnesota to cease their unlawful conduct, which includes, but is not limited to, prohibiting  racial profiling, the use of excessive force, retaliation, and enforcement at sensitive  locations; requiring that Defendants equip their agents with body-worn cameras; and  requiring that state law and Defendants' own policies be followed."

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Amanda Karras (she/her)
Executive Director / General Counsel
International Municipal Lawyers Association
P: (202) 466-5424 x7116
D: (202) 742-1018
51 Monroe St. Suite 404 Rockville, MD, 20850
Plan Ahead! See IMLA's upcoming eventshttps://urldefense.proofpoint.com/v2/url?u=https-3A__imla.org_events_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=iby47JJLZYH1wxnRzC5LcDMYr5tCJAy69ckjFIeQLQg&e=, calls and programming.

Dear IMLA Immigration Working Group:

Thank you for those that were able to participate in today's call.  Here are a couple of follow-up items:

1. If you are interested in joining the City of Boston's amicus brief in support of Minneapolis, St. Paul, and Minnesota in the case detailed in my email below (complaint attached), please email Megan Corrigan at megan.corrigan@boston.govmailto:megan.corrigan@boston.gov by COB tomorrow.

2. As noted on today's call, the city of Chicago and Illinois filed a similar lawsuit to the aforementioned Minneapolis/St. Paul/Minnesota lawsuit on 1/12.  The Chicago/Illinois suit was filed against DHS, US Customs & Enforcement, & Border Patrol and makes similar Tenth Amendment and APA claims.  The lawsuit, challenges what it characterizes as "the Trump Administration's federal overreach using tactics exceeding the authority granted by Congress, including arresting people without warrants or probable cause, indiscriminately deploying tear gas, and other illegal enforcement policies."  It claims that Border Patrol is not authorized to perform large scale removal operations in the interior of the United States.  And it alleges that the defendants have adopted and implemented a number of unlawful policies.  You can read the complaint here: https://storage.courtlistener.com/recap/gov.uscourts.ilnd.492637/gov.uscourts.ilnd.492637.1.0.pdf

3. I also wanted to flag Tincher v. Noem, which is a class action lawsuit brought by protestors in Minnesota who claim First and Fourth Amendment violations by ICE / DHS agents.  The court granted the PI motion in part and also granted class-wide relief on 1/16.  The court credited the declarations submitted by the plaintiffs, found they established a likelihood of success on the merits, and also found they had standing to sue.  The Court concluded that limited class-wide relief was appropriate at this stage, and disagreed that recent Supreme Court jurisprudence (Trump v. CASA) forecloses that relief.  The defendants noticed their appeal to the Eighth Circuit yesterday.  You can read the court's order here: https://storage.courtlistener.com/recap/gov.uscourts.mnd.229758/gov.uscourts.mnd.229758.85.0_2.pdf

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Amanda Karras (she/her)
Executive Director / General Counsel
International Municipal Lawyers Association
P: (202) 466-5424 x7116
D: (202) 742-1018
51 Monroe St. Suite 404 Rockville, MD, 20850
Plan Ahead! See IMLA's upcoming eventshttps://imla.org/events/, calls and programming.

From: Amanda Karras via Immigration immigration@lists.imla.org
Sent: Wednesday, January 14, 2026 3:43 PM
Subject: [Immigration] IMLA Immigration Working Group

Dear IMLA Immigration Working Group:

Here are some additional updates for the group.

1. President Trump indicated yesterday that he is going to suspend all federal funding to sanctuary cities and states beginning on 2/1.  https://www.politico.com/news/2026/01/13/white-house-end-funding-sanctuary-cities-states-00726557https://urldefense.proofpoint.com/v2/url?u=https-3A__www.politico.com_news_2026_01_13_white-2Dhouse-2Dend-2Dfunding-2Dsanctuary-2Dcities-2Dstates-2D00726557&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=SppcCZYKwxjUf_wGMSc7DZgVe-oBaHKN5FFX_HArzew&e=.  Please let me know if you hear anything else about this in terms of direct communication to your jurisdiction.

2. San Diego filed suit against the federal government for trespass, public nuisance and other claims in order to halt the federal government's construction of razor wire fencing on City-owned property.  The suit seeks to protect environmentally sensitive land that is part of the City's Multiple Species Conservation Program and ensure compliance with longstanding agreements to preserve critical habitats.  You can read the complaint here: https://files.constantcontact.com/7fef1c1f901/78a97f42-d0ad-4077-94b0-1e3300697e20.pdf?rdr=truehttps://urldefense.proofpoint.com/v2/url?u=https-3A__files.constantcontact.com_7fef1c1f901_78a97f42-2Dd0ad-2D4077-2D94b0-2D1e3300697e20.pdf-3Frdr-3Dtrue&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=nY090gHuuaT3aWj9Kw-NAHs510kcymcsd6kiHyxviZY&e=

3. The Ninth Circuit vacated the stay in Oregon v. Trump, the National Guard case.  This was after the defendants withdrew their request for a stay pending appeal and after representing that the Oregon National Guard members were in transit to demobilize.  https://cdn.ca9.uscourts.gov/datastore/opinions/2026/01/08/25-6268.pdfhttps://urldefense.proofpoint.com/v2/url?u=https-3A__cdn.ca9.uscourts.gov_datastore_opinions_2026_01_08_25-2D6268.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=uPHgr0zpEcQpEhfvtWXb5Qs_X9K3SNxAUc2jx8C_J7Y&e=

4. LA County has adopted a new ordinance limiting the use of county property from being used for other than county purposes, including for any civil enforcement staging, processing, or operations, including civil immigration enforcement.  You can view it here:  https://file.lacounty.gov/SDSInter/bos/supdocs/211619.pdfhttps://urldefense.proofpoint.com/v2/url?u=https-3A__file.lacounty.gov_SDSInter_bos_supdocs_211619.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=yI8nH43sOG3vZPzLdEQGVhH3LNYbbbTQZW31bzgfE3hflGjnIaw16OlHg_MXG9OW&s=PJPQEOT-tyuKek8bq8X5Gprq5ZEn64IvCmyr1zRoKhw&e=

5. I am attaching the lawsuit filed by Minnesota, Minneapolis, & St. Paul against Noem & DHS, as well as the TRO related to the surge in immigration enforcement in those jurisdictions.  The court converted the TRO to a motion for a PI and gave the defendants until 1/19/26 to respond.

The complaint highlights that the President has deployed over 2,000 DHS agents to the Twin Cities in what is being called "Operation Metro Surge" and that this number greatly exceeds the number of sworn police offices Minneapolis and St. Paul have combined.  The complaint alleges that the Defendants' actions are "interfering with the ability of state and local officials to protect and care for their residents."  And the Plaintiffs allege that the Defendants' tactics are endangering the health, safety, and welfare of the Plaintiffs' residents and that it is the state and city governments that will then bear both tangible and intangible costs as a result.

The complaint claims that the agents are engaged in racial profiling, including arresting and detaining US citizens.  It also details that the agents have been driving in unsafe and reckless ways, causing traffic accidents, engaging in warrantless arrests, and changing their license plates on their vehicles.  The complaint also alleges that the federal agents are engaging in actions intended to "spark public outrage," for example, by detaining a woman and dragging her "handcuffed across a frozen road, despite being repeatedly told by bystanders that she was pregnant."  The complaint notes that Minneapolis has received numerous 911 calls related to DHS agents engaging in inappropriate force or threats of force including brandishing guns, pepper spraying, shoving, and using tear gas.

The complaint then explains that the tactics, including aggressive enforcement at sensitive locations, has led to protests and that the defendants have engaged in unlawful conduct toward the protestors and legal observers as well.

In addition to the foregoing, the complaint includes the details of the fatal shooting of Renee Good.  Immigration enforcement activity continued that day after the shooting including at a Minneapolis high school where agents fired pepper spray at individuals in a crowd that included students, teachers, and school administrators. As a result, Minneapolis canceled public schools for two days for 30,000 students.

In terms of the impact on the cities, the complaint explains that Minneapolis has received over eighty 911 calls related to the defendants' actions, which all take time and resources away from other law enforcement functions.  Minneapolis police needed to respond to twenty-four ICE related incidents between 12/9-1/7.  And law enforcement has responded to tense protests which the complaint alleges were caused by the "Defendants' aggressive and reckless actions."  Minneapolis has begun tracking overtime related to its response to the defendants' immigration enforcement activities.  And in just 2 days, between 1/7 - 1/9, the officers had already worked more than 3,000 hours of overtime related to this activity, which is an estimated $2 million cost. Officers time off was also all canceled and they are working longer shifts as a result of this activity.  There are also details about impacts on officers' mental health and well-being.

St. Paul also indicates in the complaint that the defendants' tactics, including failing to identify themselves and wearing masks, are undermining trust in SPPD which in turn will lead to a decrease in reported crimes and cooperation with investigations. St. Paul also details DHS' unlawful commandeering of city-owned parking lots without authorization from the city.

The cities also note that the Defendants' actions have caused a decrease in retail activity, resulting in lower tax revenue.

The allegations are based on violations of

                                                          i.      The Tenth Amendment,

                                                        ii.      Equal Sovereignty Under the Constitution (brought by Minnesota only),

                                                      iii.      The APA related to violation of state law/city ordinances prohibiting individuals from concealing their identity by wearing masks in public & a state law prohibiting the misuse of license plates;

                                                       iv.      The APA as contrary to law for the use of excessive force against the plaintiffs' residents

                                                        v.      the APA by acting contrary to law and engaging in warrantless arrests without individualized assessment of immigration status

                                                       vi.      the APA as contrary to law by conducting border patrol enforcement actions as if the agents are near the border

                                                     vii.      The APA as arbitrary and capricious by revoking the 2021 sensitive locations policy

                                                   viii.      The First Amendment as unlawful retaliation and viewpoint discrimination

In their TRO, they request the Court enter a temporary restraining order to "stop Defendants' conduct causing Plaintiffs harm by: (1) ordering Defendants to cease Operation Metro Surge; and (2) ordering the agents that may lawfully remain in  Minnesota to cease their unlawful conduct, which includes, but is not limited to, prohibiting  racial profiling, the use of excessive force, retaliation, and enforcement at sensitive  locations; requiring that Defendants equip their agents with body-worn cameras; and  requiring that state law and Defendants' own policies be followed."

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Amanda Karras (she/her)
Executive Director / General Counsel
International Municipal Lawyers Association
P: (202) 466-5424 x7116
D: (202) 742-1018
51 Monroe St. Suite 404 Rockville, MD, 20850
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