Joint Case Management Statement; 

CCSF v. President Trump, et al; Case No. 17-00485

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DENNIS J. HERRERA, State Bar #139669

City Attorney 

JESSE C. SMITH, State Bar #122517 Chief Assistant City Attorney 

RONALD P. FLYNN, State Bar #184186 Chief Deputy City Attorney 

YVONNE R. MERÉ, State Bar #173594

Chief of Complex and Affirmative Litigation 

CHRISTINE VAN AKEN, State Bar #241755 

TARA M. STEELEY, State Bar #231775

MOLLIE M. LEE, State Bar #251404 

SARA J. EISENBERG, State Bar #269303

MATTHEW S. LEE, State Bar #295247

NEHA GUPTA, State Bar #308864 

Deputy City Attorneys 

City Hall, Room 234 

1 Dr. Carlton B. Goodlett Place 

San Francisco, California 94102-4602 

Telephone: (415) 554-4748 

Facsimile: (415) 554-4715 

E-Mail: brittany.feitelberg@sfgov.org 

Attorneys for Plaintiff 

CITY AND COUNTY OF SAN FRANCISCO 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

CITY AND COUNTY OF SAN 

FRANCISCO, 

 Plaintiff, 

 vs. 

DONALD J. TRUMP, President of the United 

States, UNITED STATES OF AMERICA, 

JOHN F. KELLY, Secretary of United States 

Department of Homeland Security, 

JEFFERSON B. SESSIONS III, Attorney 

General of the United States, DOES 1-100, 

 Defendants. 

Case No. 3:17-cv-00485-WHO 

JOINT CASE MANAGEMENT STATEMENT 

Date: May 2, 2017 

Time: 1:30 p.m. 

Judge: Honorable William H. Orrick 

Dept.: Courtroom 2 

Date Filed: January 31, 2017 

Trial Date: Not set 

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Joint Case Management Statement; 

CCSF v. President Trump, et al; Case No. 17-00485

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Plaintiff City and County of San Francisco (“Plaintiff” or “San Francisco”) and Defendants 

DONALD J. TRUMP, President of the United States, UNITED STATES OF AMERICA, 

JOHN F. KELLY, Secretary of the United States Department of Homeland Security, and 

JEFFERSON B. SESSIONS III, Attorney General of the United States (“Defendants”) respectfully 

submit this Joint Case Management Statement pursuant to Rules 16 and 26 of the Federal Rules of 

Civil Procedure and this Court’s Standing Order titled “Contents of Joint Case Management 

Statement.” Counsel for the parties met and conferred on these matters on April 11, 2017, and 

April 21, 2017. 

1. Jurisdiction and Service 

 San Francisco’s claims arise under the Constitution of the United States, the Tenth Amendment 

thereto, and the laws of the United States. This Court has jurisdiction under 28 U.S.C. Sections 1331 

and 1346. This Court has further remedial authority under the Declaratory Judgment Act, 28 U.S.C. 

Sections 2201 and 2202 et seq. 

 No issues exist regarding personal jurisdiction or venue, and all named defendants have been 

served. 

Plaintiff asserts that the Court has subject matter jurisdiction and that its claims are ripe. 

Defendants dispute subject matter jurisdiction on the grounds that San Francisco does not have 

standing and that its claims are not ripe. 

2. Facts 

 Plaintiff’s Statement 

 San Francisco’s body of Sanctuary City law is contained in two chapters of San Francisco’s 

Administrative Code: Chapters 12H and 12I. Chapter 12H generally prohibits San Francisco 

departments, agencies, commissions, officers, and employees from using City funds or resources to 

assist in the enforcement of Federal immigration law, and specifically prohibits using City resources to 

gather or disseminate information regarding the release status or other confidential identifying 

information of individuals, unless such assistance is required by Federal or state law. Chapter 12I 

prohibits San Francisco law enforcement officials from (1) detaining an individual who is otherwise 

eligible for release from custody on the basis of a civil immigration detainer request issued by the 

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Federal government and (2) responding to a federal immigration officer’s request for advance 

notification of the date and time an individual in San Francisco’s custody is being released, unless the 

individual in question meets certain criteria. San Francisco departments have adopted and 

implemented policies consistent with Chapters 12H and 12I. 

 On January 25, 2017, President Donald J. Trump issued Executive Order Number 13768, 

entitled “Enhancing Public Safety in the Interior of the United States.” The Executive Order declares, 

“Sanctuary jurisdictions across the United States willfully violate Federal law in an attempt to shield 

aliens from removal from the United States. These jurisdictions have caused immeasurable harm to the 

American people and to the very fabric of our Republic.” Executive Order § 1. To address the 

purported harm caused by Sanctuary Cities, the Executive Order establishes the policy that 

“jurisdictions that fail to comply with applicable Federal law do not receive Federal funds, except as 

mandated by law.” Id. at § 2. Section 9 of the Executive Order states: 

It is the policy of the executive branch to ensure, to the fullest extent of the law, 

that a State, or a political subdivision of a State, shall comply with 8 U.S.C. 

1373. 

(a) In furtherance of this policy, the Attorney General and the Secretary, in 

their discretion and to the extent consistent with law, shall ensure that 

jurisdictions that willfully refuse to comply with 8 U.S.C. 1373 (sanctuary 

jurisdictions) are not eligible to receive Federal grants, except as deemed 

necessary for law enforcement purposes by the Attorney General or the 

Secretary. The Secretary has the authority to designate, in his discretion and to 

the extent consistent with law, a jurisdiction as a sanctuary jurisdiction. The 

Attorney General shall take appropriate enforcement action against any entity 

that violates 8 U.S.C. 1373, or which has in effect a statute, policy, or practice 

that prevents or hinders the enforcement of Federal law. 

(b) To better inform the public regarding the public safety threats associated 

with sanctuary jurisdictions, the Secretary shall utilize the Declined Detainer 

Outcome Report or its equivalent and, on a weekly basis, make public a 

comprehensive list of criminal actions committed by aliens and any jurisdiction 

that ignored or otherwise failed to honor any detainers with respect to such 

aliens. 

(c) The Director of the Office of Management and Budget is directed to obtain 

and provide relevant and responsive information on all Federal grant money that 

currently is received by any sanctuary jurisdiction. 

 Defendants have made statements regarding the scope and application of this executive order 

in public, as well as in court arguments and filings. It is San Francisco’s position that it will inevitably 

be designated as a “Sanctuary Jurisdiction” and that there are remaining questions about the precise 

consequences that will flow from that designation. 

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 San Francisco’s annual operating budget for FY16-17 includes over $1.2 billion in 

federal funds. In addition, San Francisco expects to receive an additional $800 million in federal multiyear grants, largely for public infrastructure projects. 

 Defendants’ Statement 

Defendants are in the process of making several decisions and taking several steps that must be 

completed in order to implement the Executive Order. Defendants have not determined that any 

jurisdiction is a “sanctuary jurisdiction” under the Order. 

3. Legal Issues 

 Plaintiff’s Statement 

 San Francisco’s Complaint raises the following legal issues: 

A. Whether Section 9(a) of the Executive Order violates separation of powers as 

set forth in Article I, sec. 1 of the United States Constitution by exercising 

Spending Power that the Constitution grants to Congress. 

B. Whether Section 9(a) of the Executive Order violates the Tenth Amendment and 

the Spending Clause of the United States Constitution by: 

1. Imposing new funding conditions on existing federal funds; 

2. Imposing funding conditions not germane to the purpose of the funds; 

3. Imposing funding conditions so severe as to coerce compliance; and 

4. Imposing funding conditions that require jurisdictions to act 

unconstitutionally. 

C. Whether Section 9(a) of the Executive Order violates the Tenth Amendment to 

the United States Constitution by commandeering state and local governments 

by, inter alia, compelling them to comply with detainer requests. 

D. Whether 8 U.S.C. Section 1373 violates the Tenth Amendment to the United 

States Constitution on its face and as applied to San Francisco. 

E. Whether San Francisco laws and policies comply with 8 U.S.C. Section 1373. 

F. Whether San Francisco is entitled to a preliminary and permanent injunction, 

declaratory relief, and other relief as stated in the Complaint. 

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Defendants’ Statement 

This action presents the following legal issues: 

A. Whether the plaintiff’s claims are constitutionally ripe for judicial review. 

B. Whether the plaintiff satisfies the requirements for constitutional standing. 

C. Whether the plaintiff has stated a viable claim that 8 U.S.C. § 1373 violates the 

Tenth Amendment. 

D. Whether the plaintiff has stated a viable claim for declaratory relief regarding its 

compliance with 8 U.S.C. § 1373. 

E. Whether the plaintiff’s law and policies violate 8 U.S.C. § 1373. 

F. Whether 8 U.S.C. § 1373 violates the Tenth Amendment. 

G. Whether Section 9(a) of the Executive Order violates the Tenth Amendment, 

the Separation of Powers, or the Spending Clause. 

4. Motions 

 The Court heard argument on San Francisco’s Motion for Preliminary Injunction on 

April 14, 2017, and took the matter under submission. The Court issued an Order Granting the County 

of Santa Clara’s and City and County of San Francisco’s Motions to Enjoin Section 9(a) of the 

Executive Order 13768. 

Defendants anticipate filing a motion to dismiss by April 28, 2017, which will be noticed for 

hearing on June 7, 2017, if that date remains available on the Court’s calendar at the time of filing. 

San Francisco anticipates filing a motion for summary judgment and may file motions related to 

discovery disputes, if there are disputes the parties are unable to resolve. 

5. Amendment of Pleadings 

The parties do not plan to amend the pleadings. 

6. Evidence Preservation 

 The parties have reviewed the Guidelines Relating to the Discovery of Electronically Stored 

Information (“ESI Guidelines”), and have met and conferred pursuant to Fed. R. Civ. P. 26(f) 

regarding reasonable and proportionate steps taken to preserve evidence relevant to the issues 

// 

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reasonably evident in this action. The parties have begun conferring regarding ESI protocols and will 

continue to meet and confer on this topic. 

 San Francisco has put into effect procedures to preserve hard copy and electronic records 

relating to San Francisco Administrative Code Chapters 12H or 12I; the City’s Sanctuary City 

policies; and the impact of the Executive Order on the City’s budget, finances, or operations. The time 

period covered is January 12, 2016 to the present. 

 Defendants are in the process of implementing a litigation hold to preserve hard copy and 

electronic records relating to the Executive Order and its implementation. The time period covered 

will be January 25, 2017, to the present. 

7. Disclosures 

The parties will exchange the initial disclosures required by Fed. R. Civ. P. 26(a) on or before 

May 10, 2017. If Defendants have a preliminary injunction hearing on that date in City of Richmond v. 

Trump et al., 17-cv-01535-WHO, the parties agree to extend the deadline for exchange of initial 

disclosures to May 11, 2017. 

8. Discovery 

 No discovery has been taken to date. 

Plaintiff anticipates serving written discovery in April 2017, including interrogatories, requests 

for admissions, and requests for documents regarding the scope, definitions, and application of the 

Executive Order, including what federal funds are implicated; the status and designation of 

San Francisco as a Sanctuary Jurisdiction and the consequences of that designation under the 

Executive Order; Defendants’ interpretation of 8 U.S.C. Section 1373 and whether Defendants 

contend that San Francisco’s laws and policies violate 8 U.S.C. Section 1373; and Defendants’ 

position regarding the nature of detainer requests. Depending on Defendants’ responses, Plaintiff may 

serve additional discovery and/or notice depositions. Unless there are unusually protracted discovery 

disputes, Plaintiff anticipates being able to conclude discovery by Fall 2017. 

Defendants believe discovery is not appropriate until the Court has resolved subject matter 

jurisdiction in deciding Defendants’ forthcoming Motion to Dismiss. Defendants reserve the right to 

propound discovery requests upon the plaintiff. 

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The parties have agreed to electronic service for discovery. They have not agreed to any other 

proposed limitations or modifications of the discovery rules, and they have not yet considered entering 

into a stipulated e-discovery order. The parties are willing to meet and confer on this and other topics 

as necessary. 

 The parties propose the following Rule 26(f) Discovery Plan. 

A. Initial Disclosures 

As noted in item 7 above, the parties intend to exchange initial disclosures on or before 

May 10 or 11, 2017. No changes in form or substance are necessary. 

B. Discovery subjects and timing 

Plaintiff intends to propound discovery on the topics noted above. In order to facilitate 

dispositive motions, Plaintiff proposes that discovery should be complete by October 31, 

2017. 

C. Issues about disclosure, discovery, or preservation of electronically stored information 

No issues have arisen at this stage. 

D. Privilege and protections 

The parties may assert privileges and protections, and if needed, will meet and confer 

regarding a stipulated protective order. 

E. Discovery limitations 

As noted above, Defendants take the position that discovery is not appropriate until the 

Court has resolved subject matter jurisdiction in deciding Defendants’ forthcoming Motion 

to Dismiss. Plaintiff disagrees. The parties have not discussed other discovery limitations. 

F. Other orders 

The parties do not seek any discovery orders at this stage. 

9. Class Actions 

 This is not a class action. 

10. Related Cases 

This action is related to two other cases pending in the Northern District of California: 

 County of Santa Clara v. Donald J. Trump et al., 17-cv-00574-WHO 

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 City of Richmond v. Trump et al., 17-cv-01535-WHO 

The parties are aware of two other pending cases challenging Section 9 of the Executive Order 

and/or 8 U.S.C. Section 1373: 

 City of Seattle v. Trump, 2:17-cv-00497 (W.D. Wash.) 

 City of Chelsea et al. v. Trump, 1:17-cv-10214-GAO (D. Mass) 

11. Relief 

 San Francisco requests that the Court: 

A. Declare that San Francisco laws comply with Section 1373; 

B. Declare that San Francisco policies and practices comply with Section 1373; 

C. Preliminarily and permanently enjoin Defendants from designating 

San Francisco as a jurisdiction that fails to comply with Section 1373; 

D. Declare that 8 U.S.C. Section 1373(a) is unconstitutional and invalid on its face; 

E. Enjoin Defendants from enforcing Section 1373(a) or using it as a condition for 

receiving federal funds; 

F. Declare that Section 1373(a) is invalid as applied to state and local Sanctuary 

City laws, like San Francisco Administrative Code Chapters 12H and 12I, 

which were enacted for legitimate local purposes related to public health and 

safety; 

G. Preliminarily and permanently enjoin Defendants from enforcing Section 

1373(a) against jurisdictions that enact Sanctuary City laws for legitimate local 

purposes; 

H. Declare the Funding Restriction in Executive Order invalid; 

I. Preliminarily and permanently enjoin Defendants from enforcing the Funding 

Restriction in the Executive Order; 

J. Declare the Enforcement Directive in Executive Order invalid; 

K. Preliminarily and permanently enjoin unconstitutional applications of the 

Enforcement Directive in Executive Order Section 9(a); 

L. Award San Francisco reasonable costs and attorney’s fees; and 

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M. Grant any other further relief that the Court deems fit and proper. 

12. Settlement and ADR 

 The parties agree this case is unlikely to be resolved through settlement or ADR. 

13. Consent to Magistrate Judge for All Purposes 

The parties do not consent to have a magistrate judge conduct all further proceedings including 

trial and entry of judgment. 

14. Other References 

 The parties agree this case is not suitable for reference to binding arbitration, a special master, 

or the Judicial Panel on Multidistrict Litigation. 

15. Narrowing of Issues 

 Defendants’ forthcoming motion to dismiss will seek to narrow the issues in this case. 

The parties will continue to meet and confer in an attempt to narrow the issues to be decided. 

16. Expedited Trial Procedure 

The parties agree this is not the type of case that can be handled under the Expedited Trial 

Procedure of General Order No. 64. 

17. Scheduling 

The parties propose the following schedules. Defendants believe it is premature to propose 

dates for discovery cutoff, pretrial deadlines, or trial. 

Event Plaintiff’s 

Proposed Schedule 

Defendants’ 

Proposed Schedule 

Deadline for Defendants to file 

a Rule 12 Motion or otherwise 

respond to the Complaint 

April 28, 2017 April 28, 2017 

Deadline for the parties to 

exchange initial disclosures 

per Rule 26 

May 10 or 11, 2017 

(see item 7, above) 

May 10 or 11, 2017 

(see item 7, above) 

Close of fact discovery October 31, 2017 N/A 

Deadline for filing dispositive 

motions November 30, 2017 N/A 

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Event Plaintiff’s 

Proposed Schedule 

Defendants’ 

Proposed Schedule 

Last day to exchange papers 

described in Civil L.R. 16-

10(b)(7),(8),(9) and (10) and 

any motions in limine (at least 

28 days before Pre-Trial 

Conference) 

January 26, 2018 N/A 

Last day to meet and confer 

before pre-trial conference (at 

least 21 days prior to pretrial 

conference) 

February 2, 2018 N/A 

Deadline to file pre-trial 

conference statement, 

proposed Findings of Fact and 

Conclusions of Law, and 

motions in limine (at least 14 

days prior to pretrial 

conference) 

February 9, 2018 N/A 

Deadline to file response 

briefs to motions in limine (at 

least 7 days prior to pretrial 

conference) 

February 16, 2018 N/A 

Final pretrial conference February 26, 2018 N/A 

Trial March 5, 2018 N/A 

18. Trial 

The parties agree that a bench trial would be appropriate in this case, if a trial is needed. They 

estimate a trial length of five days. 

19. Disclosure of Non-Party Interested Entities or Persons 

The parties are government entities and officials; therefore Civil Local Rule 3-15 does not 

apply. 

20. Professional Conduct 

All attorneys of record have reviewed the Guidelines for Professional Conduct for the Northern 

District of California. 

// 

// 

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21. Other Matters 

The parties have no other matters to report. 

Dated: April 25, 2017 

CHAD A. READLER 

Acting Assistant Attorney General 

BRIAN STRETCH 

United States Attorney 

JOHN R. TYLER 

Assistant Director 

W. SCOTT SIMPSON 

Senior Trial Counsel 

By: /s/ W. Scott Simpson 

 W. SCOTT SIMPSON (Va. Bar #27487) 

 Senior Trial Counsel 

Attorneys, Department of Justice 

Civil Division, Room 7210 

Federal Programs Branch 

Post Office Box 883 

Washington, DC 20044 

Telephone: (202) 514-3495 

Facsimile: (202) 616-8470 

Email: scott.simpson@usdoj.gov 

COUNSEL FOR DEFENDANTS 

DONALD J. TRUMP, President of the United 

States; JOHN F. KELLY, Secretary of Homeland 

Security; JEFFERSON B. SESSIONS, III, 

Attorney General of the United States; and 

UNITED STATES OF AMERICA 

Dated: April 25, 2017 

DENNIS J. HERRERA 

City Attorney 

RONALD FLYNN 

JESSE C. SMITH 

YVONNE R. MERÉ 

CHRISTINE VAN AKEN 

TARA STEELEY 

MOLLIE M. LEE 

SARA J. EISENBERG 

MATTHEW S. LEE 

NEHA GUPTA

Deputy City Attorneys 

By: /s/ Mollie M. Lee 

 MOLLIE M. LEE 

 Deputy City Attorney 

Attorneys for Plaintiff 

CITY AND COUNTY OF SAN FRANCISCO 

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FILER’S ATTESTATION 

I, Mollie M. Lee, am the ECF user whose identification and password are being used to file 

this JOINT CASE MANAGEMENT STATEMENT. Pursuant to Civil Local Rule 5-1(i)(3), I hereby 

attest that the other above-named signatories concur in this filing. 

Dated: April 25, 2017 

By: /s/ Mollie M. Lee 

 MOLLIE M. LEE 

 Deputy City Attorney 

Attorneys for Plaintiff 

CITY AND COUNTY OF SAN FRANCISCO 

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