HomeMy WebLinkAbout04-04-2017 Item 17, Relating to Federal Immigration Enforcement Cooperation - Declaring SLO a Welcoming City to all Persons Meeting Date: 4/4/2017
FROM: Chief Deanna Cantrell
Prepared By: Christine Dietrick, City Attorney
Derek Johnson, Assistant City Manager
SUBJECT: RESOLUTION FORMALLY SETTING FORTH THE CITY’S CURRENT
POLICIES AND PRACTICES RELATING TO FEDERAL IMMIGRATION
ENFORCEMENT COOPERATION AND DECLARING SAN LUIS OBISPO
AS A WELCOMING CITY TO ALL PERSONS, IRRESPECTIVE OF
IMMIGRATION STATUS
RECOMMENDATION
Pursuant to Council direction, consider a Resolution that sets forth the City’s current policies and
practices relating to Federal immigration enforcement cooperation and declaring the City as a
welcoming city to all persons, regardless of their immigration status.
DISCUSSION
The proposed Resolution recognizes that the City of San Luis Obispo has a history of inclusion
and that the City wishes to “foster trust and cooperation” between the City, our Police
Department, and immigrant communities.
The resolution (1) calls upon all City residents, departments and employees to report acts of
“bullying, discrimination and hate violence,” and (2) states that “City employees, including
members of the San Luis Obispo Police Department, shall not directly enforce Federal civil
immigration laws and shall not use city monies, resources or personnel to investigate, question,
detect, or apprehend persons” solely for federal immigration violations, unless required by state
or federal law. This essentially articulates the City’s current practices relating to Federal
Immigration enforcement.
Background
The City of San Luis Obispo and San Luis Obispo Police Department are committed to
providing services to the community equally, fairly and without discrimination toward any
individual or group. It is currently the policy of the City of San Luis Obispo to treat all persons
equally, with dignity and respect, regardless of race, religion, creed, color, national origin,
ancestry, age, sex, sexual orientation, gender, gender identity, or disability status.
The San Luis Obispo Police Department’s mission is to “maintain a safe city… while preserving
the rights of all through a commitment to service, pride and integrity.” To achieve that mission,
the San Luis Obispo Police Department has not participated in the direct enforcement of
immigration laws. Moreover, the practice at the San Luis Obispo Police Department is to not ask
people their status in the United States, whether they are contacted as victims, witnesses or
suspects. Public safety is the primary mission of local law enforcement, not immigration. The
San Luis Obispo Police Department lacks the authority and jurisdiction to enforce federal
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immigration law. In keeping with its public safety mission, the San Luis Obispo Police
Department strongly believes that undocumented immigrants who commit violent and serious
offenses against members of our community should be subject to the immigration laws of this
country. Immigration and Customs Enforcement (ICE) and Homeland Security Investigations
(HSI) not only enforce immigration, but focus on organized crime, human trafficking, narcotics
and weapons investigations, and national security and failing to partner with any federal partner
could result in lowered public safety. As a result of this broader mission of the Federal agencies,
there are times when the San Luis Obispo Police Department should and does participate in law
enforcement activities with these Federal agencies to fulfill its mission to “maintain a safe
city….”.
On March 7, 2017, the Council directed staff to bring forward at a future meeting a resolution
formally setting forth the City’s current policies and practices relating to Federal immigration
enforcement cooperation and declaring San Luis Obispo as a welcoming city to all persons,
irrespective of immigration status. The proposed Resolution is a general statement of principles
and affirmation of existing practices. The Resolution states that the City should be safe for all
community members, regardless of immigration status; should encourage trust between
immigrant communities and law enforcement; and should not use its resources to directly
enforce Federal immigration laws.
The term “sanctuary city” generally refers to local jurisdictions that in some way limit their
cooperation with federal immigration authorities, typically by refusing to honor detention
requests from the Immigration and Customs Enforcement Service (ICE) (Brookings Institute,
February 24, 2017). Most often, such requests are directed to Counties and large cities that
operate jails, which the City does not.
The President, through an Executive Order issued in January, ordered, in relevant part, as
follows:
“Sec. 9 Sanctuary Jurisdictions. 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) …the Attorney General and the Secretary1, …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 fo r
law enforcement purposes by the Attorney General or the Secretary. The Secretary has
the authority to designate, …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 [emphasis added].
(b) … 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
1 Refers to Secretary of Homeland Security.
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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.
****
Sec. 18 (b) This order shall be implemented consistent with applicable law and subject to
the availability of appropriations.
At this point, the criteria that may be used by the Secretary of Homeland Security to designate
“sanctuary jurisdictions” is unclear, as is the scope and extent of grant funding that may be
targeted. The Order itself expressly defines jurisdictions that “willfully refuse to comply with 8
U.S.C. 1373” as sanctuary jurisdictions, subject to grant withholding under the Order. That
section reads as follows:
8 U.S. Code § 1373 - Communication between government agencies and the
Immigration and Naturalization Service
(a) In general
Notwithstanding any other provision of Federal, State, or local law, a Federal,
State, or local government entity or official may not prohibit, or in any way
restrict, any government entity or official from sending to, or receiving from, the
Immigration and Naturalization Service information regarding the citizenship or
immigration status, lawful or unlawful, of any individual.
(b) Additional authority of government entities … no person or agency may
prohibit, or in any way restrict, a … local government entity from doing any of
the following with respect to information regarding the immigration status…:
(1) Sending such information to, or requesting or receiving such inform ation
from, the Immigration and Naturalization Service.
(2) Maintaining such information.
(3) Exchanging such information with any other Federal, State, or local
government entity.
While the section prohibits local restrictions on the requests for, exchanges of, or maintenance of
immigration status information, there is nothing in the law that prohibits local restrictions on use
of local resources to inquire into, investigate or collect (rather than maintain) immigration status
information from individuals. Obviously, a jurisdiction cannot share information that it does not
collect. Thus, staff has crafted the recommended Resolution to focus on issues of inquiry and
collection of immigration information from individuals to avoid potential conflict with the
federal law referenced in the Order. In that manner, the City avoids falling within the definition
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of a sanctuary jurisdiction expressly articulated in the Order, while clearly asserting its resource
and enforcement priorities and inclusive community values.
What is significantly more ambiguous is what might constitute “a statute, policy, or practice that
prevents or hinders the enforcement of Federal law” for purposes of grant withholding. A
Federal interpretation of that language purporting to compel any direct or proactive local
immigration enforcement activity would likely run afoul of the Federal constitution on 10th
amendment grounds. Further, to the extent that the Order may be asserted to support the
withdrawal of past funding not specifically conditioned on compliance with Federal immigration
law or restrictions on prospective federal funding with no nexus to immigration issues (i.e.,
transit funding), the Order would be highly constitutionally suspect under recent US Supreme
Court authority (National Federation of Independent Businesses v. Sebelius, involving the
constitutionality of the Affordable Care Act).
At the same time, the state legislature is considering specific rules to limit law enforcement
cooperation with federal immigration authorities. Senate Bill 54, the “California Values Act”
proposes new rules for cities, counties and school districts which limits information that can be
provided to immigration authorities. Specifically, the law would repeal requirements that
arresting agencies report immigration information to Federal officials and prohibit State and
local law enforcement agencies from participating in enforcement of Federal immigration law.
Additionally, Senate Bill 54 would prohibit detaining an individual based on an immigration
hold and directs the Attorney General to publish model policies within three months.
ENVIRONMENTAL REVIEW
This action is exempt from the California Environmental Quality Act (CEQA) because it is not a
project which has a potential for resulting in either a direct physical change in the environment, or a
reasonably foreseeable indirect physical change in the environment, pursuant to CEQA Guideline
section 15378.
FISCAL IMPACT
The potential fiscal impact of passing the Resolution is uncertain. The Resolution by itself does not
generate any costs or revenues. The primary area of uncertainty relates to President’s Executive
Order should the Resolution be construed to mean that the City of San Luis Obispo has declared
itself a “sanctuary jurisdiction”.
Federal law does not require the City to enforce federal immigration laws. But the President, through
his Executive Order, has directed the Attorney General and Secretary of Homeland Security to
identify “sanctuary jurisdictions” and deprive them of Federal grant funds. At this point, it is unclear
how broadly the Federal government will identify “sanctuary jurisdictions” and which funds will be
targeted.
A lawsuit filed by the City/County of San Francisco on January 31, 2017 challenges this Exe cutive
Order. San Francisco’s lawsuit seeks a declaration that San Francisco is in compliance with 8 U.S.C.
section 1373, which prohibits restrictions on communicating with Federal immigration authorities
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about a person’s immigration status, or in the alternative, that “Section 1373 is unconstitutional on its
face and as applied to state and local Sanctuary City laws such as San Francisco’s.”
The City receives various federal funds including Community Development Block Grant, Federal
Transit and Transportation Funds, and Public Safety Funding. These funds are outlined below for
reference:
Program
City Fund Name
(e.g. General Fund,
Water Fund, etc.)
Federal Fund Type
(e.g. FAST Act, CDBG,
Fed Grant Name)
Description One-Time Amount Ongoing Amount
Transit Operations Transit Fund Federal Transit Authority
(FTA)
Grant funds for transit
operations and capital
purchases/projects
$ 1,614,500
Transit Operations Transit Fund Federal Transit Authority
(FTA)
Grant funds for transit
operations and capital
purchases/projects
$ 1,424,554
Transit Operations Transit Fund Federal Transit Authority
(FTA)3 busses $ 1,125,000
CIP Engineering General Fund Active Transportation
Program (ATP)
Grant funds for bike/pedestrian
projects (i.e. Railroad Safety
Trail - Taft to Pepper)
$ 3,244,000
Community
Development General Fund Community Development
Block Grant
Homeless Services, Affordable
Housing, Infrastructure $ 442,462
Police Law Enforcement
Grant Fund
DOJ -Edward Byrnes
Memorial Justice Assistance
Grant Program
Grant funding (non-competitive
grant) $ 15,000
Police Law Enforcement
Grant Fund
DOJ (funded under the DOJ
Appropriations Act, 2016
(PL 114-112)
Grant Funding (competitive
grant) - Body Worn Cameras $ 74,060
Police General Fund
U. S. Dept. of Justice,
Bulletproof Vest Partnership
(BVP)
Reimbursement for duty vests.
Reimburses at 50% of cost. $ 12,000
Fire General Fund US Department of
Agriculture Forest Service
Reimbursement for personnel
and equipment mutual aid
wildland fires
$ 300,000
Fire General Fund
FEMA - 1)Assistance to
Firefighter grants 2) Fire
Prevention grants 3) Local
Hazard Mitigation plan or
project
Typically for equipment or fire
prevention program or hazard
mitigation
Varies
Fire General Fund National Fire Academy
and/or Emergency
Management Institute (both
are under FEMA)
Provides reimbursement for
eligible participation in training
and education programs,
including those on the campus
of the National Fire Academy in
Maryland.
Varies
CIP Engineering General Fund Highway Bridge Program
(HBR)
Grant funds for the Marsh
Street Bridge Replacement
project.
$ 7,385,970
TOTAL: $ 11,829,030 $ 3,808,516
ALTERNATIVES
The City Council could decide to alter the draft Resolution or decide not to adopt a Resolution.
Attachments:
a - Draft City of San Luis Obispo Resolution
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R ______
RESOLUTION NO. ____________ (2017 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, FORMALLY SETTING FORTH THE CITY’S
CURRENT POLICIES AND PRACTICES RELATING TO FEDERAL
IMMIGRATION ENFORCEMENT COOPERATION AND DECLARING
SAN LUIS OBISPO AS A WELCOMING CITY TO ALL PERSONS,
IRRESPECTIVE OF PROTECTED CHARACTERISTICS OR
IMMIGRATION STATUS
WHEREAS, the City of San Luis Obispo is made up of diverse individuals, both native
born and immigrants, whose collective cultures, religions, backgrounds, orientations, abilities and
viewpoints join to form a community that prides itself on being a place that welcomes persons and
families of all walks of life; and
WHEREAS, recent Executive Orders and statements of federal officials have created a
sense of uncertainty and fear among many communities in San Luis Obispo, across our State and
across the Nation; and
WHEREAS, the City of San Luis Obispo assures all members of its community that the
City supports them, will do all it can to maintain and improve their quality of life, and will not
tolerate acts of hate, discrimination, bullying, or harassment; and
WHEREAS, the San Luis Obispo City Council wishes to declare that San Luis Obispo is
a safe place for immigrants from all countries, and of all races, religions, ethnicities, disabilities,
and sexual and gender identities, including the estimated 9,000 undocumented immigrants in SLO
county (Public Policy Institute of California, 2013) and their loved ones; and
WHEREAS, San Luis Obispo’s immigrant families contribute to the economic and social
fabric of the City by establishing and patronizing businesses, contributing to arts and culture, and
achieving other accomplishments which benefit not only themselves and their families, but the
entire community; and
WHEREAS, it is the City Council's desire to ensure that its immigrant residents participate
in civic life and daily activities and engage constructively with law enforcement and other City
services without fear of being arrested or reported to the United States Immigration and Customs
Enforcement agency solely due to their immigration status; and
WHEREAS, many children who are native to the United States or are undocumented
immigrants have been separated from their families by United States Immigration & Customs
Enforcement Agency due to their parents' or their personal immigration status; and
WHEREAS, it is the policy of the City of San Luis Obispo to treat all persons equally,
with dignity and respect, regardless of race, religion, creed, color, national origin, ancestry, age,
sex, sexual orientation, gender, gender identity, or disability status; and
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Resolution No. _____ (2017 Series) Page 2
R ______
WHEREAS, the San Luis Obispo Police Department is committed to providing law
enforcement services to all community members by enforcing the law equally, fairly and without
discrimination toward any individual or group, regardless of race, religion, creed, color, national
origin, ancestry, age, sex, sexual orientation, gender, gender identity, and disability status; and
WHEREAS, the San Luis Obispo Police Department recognizes the need for a safe
community and values a positive and trusting relationship with all community members they are
sworn to protect; and
WHEREAS, to encourage crime reporting and cooperation in the investigation of criminal
activity, all individuals, regardless of their immigration status, must feel secure that contacting or
being addressed by members of law enforcement will not automatically lead to immigration
inquiry and/or deportation actions initiated by the local police; and
WHEREAS, the enforcement of civil immigration laws by local police agencies raises
many complex legal, logistical and resource issues for cities, including the potential to undermine
the trust and cooperation with immigrant communities; and
WHEREAS, the City of San Luis Obispo Council is greatly concerned about public safety
in San Luis Obispo and the mission of the San Luis Obispo Police Department is to maintain a
safe city by working in partnership with the community to protect life and property, prevent and
reduce crime, and improve the quality of life in our neighborhoods, while preserving the rights of
all through a commitment to Service, Pride and Integrity,
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo
as follows:
SECTION 1. The San Luis Obispo City Council calls upon all City residents and all City
Departments and employees to speak out against acts of bullying, discrimination and hate violence
and report any alleged hate crimes to appropriate law enforcement agencies.
SECTION 2. City officials and employees, including members of the San Luis Obispo
Police Department, shall not directly enforce Federal civil immigration laws and shall not use city
monies, resources or personnel to investigate, question, detect, or apprehend persons based on
uncertainty regarding immigration status or solely on a possible violation of immigration law,
unless required by State or Federal law.
SECTION 3. The City of San Luis Police Department has adopted and implements
Police Department policy 443.2 regarding immigration violations which states “It is the policy of
the San Luis Obispo Police Department that all members make personal and professional
commitments to equal enforcement of the law and equal service to the public. Confidence in this
commitment will increase the effectiveness of the Police Department in protecting and serving
the entire community and recognizing the dignity of all persons, regardless of their immigration
status.” The practice is that the Police Department does not ask people their status in the United
States whether being contacted as victims, witnesses or suspects.
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Resolution No. _____ (2017 Series) Page 3
R ______
SECTION 4. Nothing herein is intended, nor shall it be construed, to direct non-
compliance with state or federal law.
SECTION 5. Effective Date. This Resolution is effective immediately upon adoption.
Upon motion of _______________________, seconded by _______________________,
and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this _____ day of _____________________, 2017.
____________________________________
Mayor Heidi Harmon
ATTEST:
____________________________________
Carrie Gallagher
City Clerk
APPROVED AS TO FORM:
_____________________________________
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, this ______ day of ______________, _________.
____________________________________
Carrie Gallagher
City Clerk
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