Dear IMLA Immigration Working Group: Thanks to those that joined yesterday's call. Here are a few follow-ups: 1. Here is a link to the HHS Press Release noting the agency is formally rescinding its 1998 interpretation of PRWORA which extended certain public benefits to undocumented immigrants. The list of benefits includes Head Start as well as certain health clinics. https://www.hhs.gov/press-room/prwora-hhs-bans-illegal-aliens-accessing-taxpayer-funded-programs.html 1. I am attaching San Francisco's Memo re: Limits on US ICE Search Authority that was issued to the public. (Note that some of this memorandum relies on specific state law requirements). 1. I am attaching a couple of documents related to a new case we discussed on yesterday's call. Both the City and County of Los Angeles as well as several other California cities have filed a motion to intervene in Vasquez Perdomo v. Noem. I am attaching the complaint in intervention (Called "Exhibit A" attached) as well as the memorandum of points and authorities. The lead complaint was filed on July 2, 2025, and challenges what it calls the federal governments "use of unlawful searches and seizures to terrorize residents under the guise of federal immigration enforcement." The cities' complaint in intervention describes how the federal governments immigration raids are impairing their ability to maintain law and order. The complaint explains that victims and witnesses of crimes are unwilling to cooperate with local law enforcement as a result of the raids. It also details the harm the cities have experienced, including financial harm as a result of employees and customers for local businesses being afraid to leave their homes, which has had a significant impact on tax revenue for the cities. The proposed intervenor cities also detail the overtime and direct costs they have incurred by way of responding to the immigration enforcement actions, which many residents believe to be kidnappings (because the agents are often masked and not in uniform and do not identify themselves so residents have been calling 911 and local law enforcement then needs to respond to try to calm the crowds). The complaint also details US citizens being caught up in the enforcement actions by federal immigration enforcement officers and how these raids have spread fear to the localities' residents, who believe that individuals are being racially profiled, and this has resulted in large numbers of residents refusing to leave their homes. In terms of the financial harms, the complaint explains, for example: LAPD has had to divert resources to responding to and managing the fallout from federal enforcement efforts. Since June 6, 2025, LAPD has devoted more than 10,000 personnel (measured in days of deployment) and has spent more than $27 .8 million in total costs in responding to and managing the fallout from Defendants' actions, including in receiving and responding to numerous 911 calls or other reports about federal raids or other reports of "crimes" that turned out to be federal immigration enforcement actions. ... Defendants' actions have also chilled economic activity in Los Angeles. Ridership for DASH, Los Angeles' public bus service, has declined across the City, with downtown DASH ridership for June 2025 down 35% from the prior year. Restaurants and retail businesses have emptied out. Owners report declines in sales and employees who are not showing up for work. Some businesses are reporting up to 75% declines in foot traffic and sales. Los Angeles has lost both sales and business tax income as a consequence. As far as the legal allegations, the complaint in intervention alleges the following violations: * The Fourth Amendment ("Defendants have a policy, pattern, and practice of stopping individuals without regard to reasonable suspicion that they are unlawfully in the United States"), * 8 USC s. 1357a2 (warrantless arrests without probable cause of flight risk), * 8 CFR s. 287.8(c)(ii) (standards for stops and warrantless arrests - the allegations are that they have a policy, pattern, and practice of not timely identifying themselves, their authority to execute an immigration arrest, or the reason for an arrest), * The APA (agency action exceeding statutory authority based on California law that prohibits arrests at courthouses and the lack of Congressional authority to contravene state law on this point) * The APA based on agency action that is contrary to a constitutional right (the Tenth Amendment). * The APA as being arbitrary and capricious based on the courthouse arrest policy * The Tenth Amendment (based on arresting residents around state courthouses, which the complaint alleges interferes the California's core sovereign judicial and police functions As always if you have additional information to share, please forward it to me or feel free to share with the list. Thanks, Amanda [logo]<https://imla.org/> [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> 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 events<https://imla.org/events/>, calls and programming.