Dear IMLA Immigration Working Group: This is a reminder that we have a call today at 2 pm eastern. You can join the zoom here: https://us06web.zoom.us/j/81204530388. Also, there was a new lawsuit filed by a coalition of states entitled New York v. U.S. Department of Justice, centering on the government's new interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). PRWORA restricts access to certain public benefits to U.S. citizens and "qualified aliens" and requires States to verify a person's lawful status before allowing them access to certain public benefits (e.g., Medicaid & TANF). Since PRWORA's enactment, federal agencies have interpreted PRWORA to not require States to check an individual's eligibility for other community programs like food banks, Head Start, substance abuse clinics, and homeless and domestic violence shelters. The Complaint outlines that in the last two weeks, four agencies (DOJ, HHS, ED, and DOL) have changed their longstanding interpretation of PRWORA, now requiring states (and local governments) to verity eligibility for these types of community programs. The States argue that many of these types of programs cannot realistically verify eligibility given the nature of the services, such as 27/7 crisis hotlines, emergency services for individuals suffering from overdoses, and homeless shelters. They also point out that many vulnerable people, including U.S. citizens may lack documentation to verify their eligibility for these types of services. The States argue: * The new requirements violate the APA by failing to allow for a notice and comment period for these substantive rules; * The agencies violated the APA by acting in an arbitrary and capricious way by failing to consider the States' reliance interests and because they failed to provide a reasoned basis for their decision * The agencies violated the APA because their actions were contrary to law. (For example, the statute applies to "postsecondary education ... benefits" but the new rules would apply to Head Start. The States also argue the application of PRWORA to apply to block grants funded to state and local governments contradicts the text of PRWORA). * The PRWORA notices violate the Spending Clause because the States did not receive "fair notice" of the conditions on the receipt of their federal funds and here, the agencies have had an interpretation for decades that would not include the contested benefits under PRWORA and they never hinted they would revisit their interpretations in such an immediate way. The States argue they therefore did not accept the conditions "knowingly and voluntarily." They also argue the financial inducement is impermissibly coercive given the fact that the funds at issue provide the States with billions in funding annually. The States are seeking a declaration at the notices promulgated by the agencies are unlawful and violate the APA and that the court should then vacate the notices and stay them pursuant to the APA. The States also seek a declaratory judgment that the notices violate the Constitution and seek an injunction barring the defendants from implementing them. You can access the complaint here: https://oag.ca.gov/system/files/attachments/press-docs/25-cv-00345%20-%20State%20of%20New%20York%20et%20al.%20v.%20Department%20of%20Justice%20et%20al.%20-%20Complaint.pdf And here is the motion for a PI: https://oag.ca.gov/system/files/attachments/press-docs/25-cv-00345%20-%20NY%20v.%20DOJ%20-%20Motion%20for%20PI.pdf [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.

Dear IMLA Immigration Working Group: Thank you for those that participated in todays' call. Here are a few other updates: 1. San Francisco v. Trump. The federal government filed its opposition to the plaintiffs' motion for leave to file a second amended complaint based on venue and joinder. You can review it here: https://storage.courtlistener.com/recap/gov.uscourts.cand.444175/gov.uscourts.cand.444175.173.0.pdf 1. Mayor Wu (Boston) signed an Executive Order seeking information on immigration enforcement in the city. The EO directs that the city shall regularly submit FOIA requests to DHS concerning federal immigration activity in the City, "including to ascertain the date, time, and location of enforcement activity; the names of individuals who are arrested or detained; and the alleged criminal conduct for which they were arrested or detained." Here's a copy of the EO: https://cdn.grove.wgbh.org/44/4a/5e288faf4243b2cdc381ed760332/executive-order-due-process-rights-of-bostonians-and-seeking-information-of-immigrantion-enforcement.pdf?_gl=1*1f87taq*_ga*MTAzNjU1OTI2My4xNzUzMjk3MDQy*_ga_325HS3KQKC*czE3NTMyOTcwNDIkbzEkZzAkdDE3NTMyOTcwNDQkajU4JGwwJGgw. 1. There are a couple of pending bills being proposed at the state level that would prohibit masking by law enforcement agents (NY state's MELT Act and CA's SB 627: https://legiscan.com/CA/text/SB627/id/3256182). 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. From: Amanda Karras via Immigration <immigration@lists.imla.org> Sent: Wednesday, July 23, 2025 12:02 PM Cc: immigration@lists.imla.org Subject: [Immigration] IMLA Immigration Working Group Dear IMLA Immigration Working Group: This is a reminder that we have a call today at 2 pm eastern. You can join the zoom here: https://us06web.zoom.us/j/81204530388<https://urldefense.proofpoint.com/v2/url?u=https-3A__us06web.zoom.us_j_81204530388&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=AhhyEBWwshZJByUqUJIJul3sbWbgD1zDJlcFPtBFCoU&e=>. Also, there was a new lawsuit filed by a coalition of states entitled New York v. U.S. Department of Justice, centering on the government's new interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA). PRWORA restricts access to certain public benefits to U.S. citizens and "qualified aliens" and requires States to verify a person's lawful status before allowing them access to certain public benefits (e.g., Medicaid & TANF). Since PRWORA's enactment, federal agencies have interpreted PRWORA to not require States to check an individual's eligibility for other community programs like food banks, Head Start, substance abuse clinics, and homeless and domestic violence shelters. The Complaint outlines that in the last two weeks, four agencies (DOJ, HHS, ED, and DOL) have changed their longstanding interpretation of PRWORA, now requiring states (and local governments) to verity eligibility for these types of community programs. The States argue that many of these types of programs cannot realistically verify eligibility given the nature of the services, such as 27/7 crisis hotlines, emergency services for individuals suffering from overdoses, and homeless shelters. They also point out that many vulnerable people, including U.S. citizens may lack documentation to verify their eligibility for these types of services. The States argue: * The new requirements violate the APA by failing to allow for a notice and comment period for these substantive rules; * The agencies violated the APA by acting in an arbitrary and capricious way by failing to consider the States' reliance interests and because they failed to provide a reasoned basis for their decision * The agencies violated the APA because their actions were contrary to law. (For example, the statute applies to "postsecondary education ... benefits" but the new rules would apply to Head Start. The States also argue the application of PRWORA to apply to block grants funded to state and local governments contradicts the text of PRWORA). * The PRWORA notices violate the Spending Clause because the States did not receive "fair notice" of the conditions on the receipt of their federal funds and here, the agencies have had an interpretation for decades that would not include the contested benefits under PRWORA and they never hinted they would revisit their interpretations in such an immediate way. The States argue they therefore did not accept the conditions "knowingly and voluntarily." They also argue the financial inducement is impermissibly coercive given the fact that the funds at issue provide the States with billions in funding annually. The States are seeking a declaration at the notices promulgated by the agencies are unlawful and violate the APA and that the court should then vacate the notices and stay them pursuant to the APA. The States also seek a declaratory judgment that the notices violate the Constitution and seek an injunction barring the defendants from implementing them. You can access the complaint here: https://oag.ca.gov/system/files/attachments/press-docs/25-cv-00345%20-%20State%20of%20New%20York%20et%20al.%20v.%20Department%20of%20Justice%20et%20al.%20-%20Complaint.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__oag.ca.gov_system_files_attachments_press-2Ddocs_25-2Dcv-2D00345-2520-2D-2520State-2520of-2520New-2520York-2520et-2520al.-2520v.-2520Department-2520of-2520Justice-2520et-2520al.-2520-2D-2520Complaint.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=6AQVFN36uWKvL4fzmH8yD1XEeiWjmmdQOq4gStqg0do&e=> And here is the motion for a PI: https://oag.ca.gov/system/files/attachments/press-docs/25-cv-00345%20-%20NY%20v.%20DOJ%20-%20Motion%20for%20PI.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__oag.ca.gov_system_files_attachments_press-2Ddocs_25-2Dcv-2D00345-2520-2D-2520NY-2520v.-2520DOJ-2520-2D-2520Motion-2520for-2520PI.pdf&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=uARNg-AHHtkTQFMeIChJBNislLi9OlgYSG0SyHIR3ZU&e=> [logo]<https://urldefense.proofpoint.com/v2/url?u=https-3A__imla.org_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=I-paXlL0sGOnooQsta0FB8nA8xwCpWfghTu5OHh-Uvs&e=> [facebook icon]<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.facebook.com_InternationalMunicipalLawyersAssociation_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=lpysQYCg5Td4IV3wQT5MA8bf2EtmgbafitbE_0-Kr_c&e=>[twitter icon]<https://urldefense.proofpoint.com/v2/url?u=https-3A__twitter.com_imlalegal&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=PLZpUHj5ybJk2IO5g4xEa6VdwIqYK1OIGRol2GJre7E&e=>[linkedin icon]<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.linkedin.com_company_international-2Dmunicipal-2Dlawyers-2Dassociation-2Dinc._&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=yEqDejA9gOk27iGKGtpUDhH5tcaE61ZPypZTK5FkHeo&e=> 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://urldefense.proofpoint.com/v2/url?u=https-3A__imla.org_events_&d=DwMFAg&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=jblVzryv37xz6dGHTIBd0omyr7IZ_ghleJygNWPo2JE&m=VHfqUWqyjINAFz8pJOB6gxNfaMTD71qIrcPt1GJliK0IiG3na8ef2ynqXTXhpB3O&s=qRsuiV-d1DHpl_OUEBbL5Wc2dkIEz_wCB1FqUh-opyc&e=>, calls and programming.