MOT. FOR LEAVE TO FILE AMICI CURIAE BRIEF ISO PLAINTIFF’S MOTION FOR PI 

BY INDIVIDUAL SHERIFFS AND POLICE CHIEFS 

Case No. 3:17-cv-00485 

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MATTHEW J. PIERS (IL #2206161) 

CHIRAG G. BADLANI (IL #6308523) 

CARYN C. LEDERER (IL #6304495) 

HUGHES SOCOL PIERS RESNICK & DYM, LTD. 

70 West Madison St., Suite 4000 

Chicago, IL 60602 

Telephone: (312) 580-0100 

Fax: (312) 604-2623 

E-mail: mpiers@hsplegal.com 

Attorneys for Amici Curiae Individual Sheriffs 

and Police Chiefs 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

CITY AND COUNTY OF SAN FRANCISCO, 

Plaintiff, 

v. 

DONALD J. TRUMP, et al., 

Defendants. 

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

MOTION FOR LEAVE TO FILE 

AMICI CURIAE BRIEF IN 

SUPPORT OF PLAINTIFF’S 

MOTION FOR PRELIMINARY 

INJUNCTION BY INDIVIDUAL 

SHERIFFS AND POLICE CHIEFS 

Date: April 14, 2017 

Time: 2:00pm 

Dep’t: Courtroom 2 

Judge: Hon. William H. Orrick 

Date Filed: March 29, 2017 

Trial Date: Not yet set 

 

Case 3:17-cv-00485-WHO Document 59 Filed 03/29/17 Page 1 of 5
MOT. FOR LEAVE TO FILE AMICI CURIAE BRIEF ISO PLAINTIFF’S MOTION FOR PI 

BY INDIVIDUAL SHERIFFS AND POLICE CHIEFS 

Case No. 3:17-cv-00485 

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Pursuant to the Court’s March 21, 2017 Order Regarding Amicus Briefing (Dkt. No. 31), 

Movants, certain individual Sheriffs and Police Chiefs respectfully request leave to participate as 

amici curiae and file a brief in support of Plaintiff’s Motion for Preliminary Injunction. The 

proposed brief is submitted with this motion. 

I. Interest of Proposed Amici 

Amici are individual police chiefs and sheriffs from cities and counties in eleven states. 

Amici have extensive expertise in local law enforcement and in cooperative federal-state law 

enforcement activities. 

The following amici represent some of the more than 400 municipalities and counties that 

have policies limiting local involvement in federal immigration operations: 

 Chief Art Acevedo, Houston, Texas, Police Department; 

 Chief Charles Beck, Los Angeles, California, Police Department;

 Chief Chris Burbank (retired), Salt Lake City, Utah, Police Department; 

 Sheriff Jerry Clayton, Washtenaw County, Michigan, Sheriff’s Office; 

 Sheriff Mark Curran, Lake County, Illinois, Sheriff’s Office; 

 Sheriff Tony Estrada, Santa Cruz County, Arizona, Sheriff’s Office; 

 Sheriff Michael Haley (retired), Washoe County, Nevada, Sheriff’s Office; 

 Sheriff Bill McCarthy, Polk County, Iowa, Sheriff’s Office; 

 Sheriff Joe Pelle, Boulder County, Colorado, Sheriff’s Office; 

 Chief Celestino Rivera, Lorain, Ohio, Police Department; 

 Sheriff John Urquhart, King County, Washington, Sheriff’s Office; 

 Sheriff Lupe Valdez, Dallas County, Texas, Sheriff’s Department; and 

Case 3:17-cv-00485-WHO Document 59 Filed 03/29/17 Page 2 of 5
MOT. FOR LEAVE TO FILE AMICI CURIAE BRIEF ISO PLAINTIFF’S MOTION FOR PI 

BY INDIVIDUAL SHERIFFS AND POLICE CHIEFS 

Case No. 3:17-cv-00485 

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 Sheriff Richard Wiles, El Paso County, Texas, Sheriff’s Office.

II. Proposed Amici’s Brief is Useful to the Court 

In their accompanying brief, proposed amici supplement Plaintiff’s Motion for Preliminary 

Injunction by drawing on their knowledge and experiences with local law enforcement practices 

and effective policing. In particular, proposed amici demonstrate that Executive Order 13768, 

which seeks to compel local law enforcement to take part in federal immigration enforcement, 

including by honoring Immigration and Customs Enforcement (“ICE”) civil detainers,1

 will 

threaten public safety by undermining community policing efforts, decreasing reporting of crime 

and cooperation with police by immigrant communities, and forcing reallocation of limited 

resources from effective public safety efforts. Proposed amici also explain that because federal 

courts across the country have held that the detention of individuals under ICE detainers who 

would otherwise be released from custody violates the Fourth Amendment of the United States 

Constitution, a preliminary injunction is necessary to halt this attempt to coerce local law 

enforcement officers and agencies into a practice that would likely result in widespread 

constitutional violations and substantial civil liability. 

The information presented by proposed amici will aid the Court in assessing the balance 

of the equities and the public interest put at issue by Plaintiff’s Motion for Preliminary Injunction. 

CONCLUSION 

Proposed amici respectfully request that this Court grant this motion, allow them to 

participate as amici curiae, and accept for filing the brief submitted with this motion. 

                                                            

1

 ICE detainers are requests from ICE to hold an individual in local governmental custody to allow 

ICE to take the individual into federal custody. 

Case 3:17-cv-00485-WHO Document 59 Filed 03/29/17 Page 3 of 5
MOT. FOR LEAVE TO FILE AMICI CURIAE BRIEF ISO PLAINTIFF’S MOTION FOR PI 

BY INDIVIDUAL SHERIFFS AND POLICE CHIEFS 

Case No. 3:17-cv-00485 

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March 29, 2017 Respectfully Submitted, 

/s/ Matthew J. Piers 

Matthew J. Piers 

Chirag G. Badlani 

Caryn C. Lederer 

HUGHES SOCOL PIERS RESNICK & DYM, LTD. 

70 West Madison St., Suite 4000 

Chicago, IL 60602 

(312) 580-0100 

Counsel for Amici 

 

Case 3:17-cv-00485-WHO Document 59 Filed 03/29/17 Page 4 of 5
MOT. FOR LEAVE TO FILE AMICI CURIAE BRIEF ISO PLAINTIFF’S MOTION FOR PI 

BY INDIVIDUAL SHERIFFS AND POLICE CHIEFS 

Case No. 3:17-cv-00485 

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CERTIFICATE OF SERVICE 

I hereby certify that service of the foregoing motion and proposed brief will be delivered 

electronically on March 29, 2017, to counsel for Plaintiff and Defendants through the District’s 

Electronic Case Filing system. 

/s/ Matthew J. Piers 

Case 3:17-cv-00485-WHO Document 59 Filed 03/29/17 Page 5 of 5