JudicialPedia Logo
    • What’s In Your Toolbox?
      • ADA Advocate
      • Cash Courts vs. Constitutional Courts
      • Judicial Complaint against a Judge
      • Professional Code of Ethics
      • Resources
      • The Constitution
      • The Grand Jury
    • Browse Cases
    • Support
      • Contact Us
      • Donate
      • Partner
      • Thank You
    Add Case / Complaint
    Sign in or Register
    Add Case / Complaint

    Texas and Missouri v. Biden, USA, Alejandro Mayorkas, DHS, Troy Miller, US Customs and Border Protection, Tae Johnson, US Immigration and Customs Enforcement, Tracy Renaud, US Citizenship and Immigration Services Verified listing

    • Date
      April 13, 2021
    • City/County
      Amarillo, Texas
    • Type of Case
      Migrant Protection Protocols, Arbitrary and Capricious decisions, Unlawful immigration of the Southern Border, Immigration and Nationality Act, 8 U.S.C. § 1101 et seq., e 8 U.S.C. § 1225(b)(2)(C). The Secretary of Homeland Security
    • Case Details
    • prev
    • next
    • Bookmark
    • Copy link
    • Share
    • Report
    • prev
    • next
    Title

    Texas and Missouri v. Biden, USA, Alejandro Mayorkas, DHS, Troy Miller, US Customs and Border Protection, Tae Johnson, US Immigration and Customs Enforcement, Tracy Renaud, US Citizenship and Immigration Services

    Case Number

    2:21-cv-00067-Z

    State or Country
    Texas
    Judges

    Judge Matthew Joseph Kacsmaryk

    Defendant

    JOSEPH R. BIDEN, JR.,
    in his official capacity as
    President of the United States of
    America;

    The UNITED STATES OF AMERICA;

    ALEJANDRO MAYORKAS, )
    in his official capacity as )
    Secretary of the United States )
    Department of Homeland Security; )
    )
    UNITED STATES DEPARTMENT OF )
    HOMELAND SECURITY; )
    )
    TROY MILLER, )
    in his official capacity as )
    Acting Commissioner of the )
    United States Customs and Border )
    Protection; )
    )
    UNITED STATES CUSTOMS AND BORDER )
    PROTECTION; )
    )
    TAE JOHNSON, )
    in his official capacity as )
    Acting Director of the )
    United States Immigration and
    Customs Enforcement;
    )
    UNITED STATES IMMIGRATION AND
    CUSTOMS ENFORCEMENT;

    TRACY RENAUD,
    in her official capacity as
    Acting Director of the United States
    Citizenship and Immigration Services; and

    UNITED STATES CITIZENSHIP AND
    IMMIGRATION SERVICES,

    Plaintiff Attorney

    State of Missouri
    REPRESENTED BY

    Dean John Sauer
    (573) 751-8870
    Fax: (573) 751-0774
    Missouri Attorney General
    207 W High St
    Jefferson City, MO 65101

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    PRO HAC VICE

    Jesus A Osete
    (573) 751-1800
    Fax: (573) 751-0774
    Missouri Attorney General
    207 W High St
    Jefferson City, MO 65101

    ATTORNEY TO BE NOTICED

    PRO HAC VICE

    William Thomas Thompson
    (512) 936-2567
    Fax: (512) 457-4410
    Office of the Attorney General, Special Litigation Unit
    P.O. Box 12548 (MC-076)
    Austin, TX 78711-2548

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    State of Texas
    REPRESENTED BY

    Patrick K Sweeten
    (512) 463-4139
    Fax: (512) 457-4410
    Office of the Attorney General
    P O Box 12548
    Capitol Station, Austin, TX 78711-2548

    ATTORNEY TO BE NOTICED

    Ryan Daniel Walters
    (512) 936-2714
    Fax: (512) 457-4410
    Office of Attorney General
    P.O. Box 12548, MC 009
    Austin, TX 78711

    ATTORNEY TO BE NOTICED

    William Thomas Thompson
    (512) 936-2567
    Fax: (512) 457-4410
    Office of the Attorney General, Special Litigation Unit
    P.O. Box 12548 (MC-076)
    Austin, TX 78711-2548

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Intervener

    Advocates for Victims of Illegal Alien Crime
    REPRESENTED BY

    Walter Stephen Zimolong , III
    (215) 665-0842
    Zimolong, LLC
    353 West Lancaster Ave
    Ste 300
    Wayne, PA 19087

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Immigration Reform Law Institute
    REPRESENTED BY

    Matt Austin Crapo
    (571) 435-3582
    Matt Austin Crapo
    6850 Rolling Creek Way
    Alexandria, VA 22315

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    PRO HAC VICE

    Social Networks
    • Other
    • Website
    • Other
    Document Links 1 (Scribd et. al)

    https://storage.courtlistener.com/recap/gov.uscourts.txnd.346680/gov.uscourts.txnd.346680.1.0_1.pdf

    Document Link 2

    https://www.courtlistener.com/docket/59815977/state-of-texas-v-joseph-r-biden/

    Date
    April 13, 2021
    Type of Case
    Migrant Protection Protocols, Arbitrary and Capricious decisions, Unlawful immigration of the Southern Border, Immigration and Nationality Act, 8 U.S.C. § 1101 et seq., e 8 U.S.C. § 1225(b)(2)(C). The Secretary of Homeland Security
    The Court the Case was filed in

    United States District Court Northern District of Texas Amarillo Division

    County/City:
    Amarillo, Texas
    Plaintiff

    THE STATE OF TEXAS and

    THE STATE OF MISSOURI,

    Defendant Attorney

    Alejandro Mayorkas
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Joseph R Biden, Jr
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Tae Johnson
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Tracy Renaud
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Troy Miller
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    United States Citizenship and Immigration Services
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    United States Department of Homeland Security
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    United States Immigration and Customs Enforcement
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    United States of America
    REPRESENTED BY

    Brian C Ward
    (202) 616-9121
    Fax: (202) 305-7000
    U.S. Department of Justice
    Po Box 868
    Ben Franklin Station, Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Brian Walters Stoltz-DOJ
    (214) 659-8626
    US Attorney's Office
    1100 Commerce St
    Third Floor, Dallas, TX 75242

    ATTORNEY TO BE NOTICED

    Erez Reuveni
    (202) 307-4293
    Fax: (202) 616-8962
    US Department of Justice, Civil Division
    450 5th St., NW
    Washington, DC 20530

    ATTORNEY TO BE NOTICED

    LEAD ATTORNEY

    Francesca Marie Genova
    (202) 305-1062
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    TERMINATED: 07/27/2021 (July 27, 2021)

    Joseph Anton Darrow
    (202) 598-7537
    Fax: (202) 305-7000
    US Department of Justice, Civil Division Office of Immigration Litigation
    P O Box 868 Ben Franklin Station
    Washington, DC 20044

    ATTORNEY TO BE NOTICED

    Comments

    COMPLAINT

    1. In the first several hours following President Biden’s inauguration, the
    incoming Administration suspended the successful Migrant Protection Protocols
    (“MPP”). These regulations required individuals who both lacked a legal basis to be
    present in the United States and who had passed through Mexico en route to the
    United States to remain in Mexico pending adjudication of their immigration claims.
    Prior to the MPP, individuals passing through Mexico could enter the United States,
    raise asylum claims, expect to be released into the United States in violation of
    statutory requirements mandating their detention, and stay in the U.S. for years
    pending the resolution of their claims—even though most were ultimately rejected in
    court. MPP changed the incentives for economic migrants with weak asylum claims,
    and therefore reduced the flow of aliens—including aliens who are victims of human
    trafficking—to the southern border.
    2. This lawsuit challenges the Administration’s unexplained and
    inexplicable two-sentence statement functionally ending the MPP. The result of this
    arbitrary and capricious decision has been a huge surge of Central American
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 2 of 40 PageID 2
    3
    migrants, including thousands of unaccompanied minors, passing through Mexico in
    order to advance meritless asylum claims at the U.S. border.
    3. This migrant surge has inflicted serious costs on Texas as organized
    crime and drug cartels prey on migrant communities and children through human
    trafficking, violence, extortion, sexual assault, and exploitation. These crimes
    directly affect Texas and its border communities, especially given Texas’s strong focus
    on combating human trafficking both at the border and throughout the State. The
    additional costs of housing, educating, and providing healthcare and other social
    services for trafficking victims or illegal aliens further burden Texas and its
    taxpayers.
    4. The effects of unlawful immigration do not stop at the southern border.
    Indeed, “[t]he pervasiveness of federal regulation does not diminish the importance
    of immigration policy to the States[,]” which “bear[] many of the consequences of
    unlawful immigration.” Arizona v. United States, 567 U.S. 387, 397 (2012). With its
    intersection of major interstate highway routes, Missouri is a major destination and
    hub for human trafficking. Missouri’s ongoing fight against human trafficking—
    including the exploitation and trafficking of vulnerable migrants—likewise provides
    it with justiciable interests that fall within the zone of interests of federal statutes on
    immigration-related policy. Indeed, irresponsible border-security policies that invite
    and encourage human traffickers to exploit vulnerable border-crossing victims
    irreparably injure Missouri and other States.
    5. Recently, Texas’s and Missouri’s interests in combating human
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 3 of 40 PageID 3
    4
    trafficking have become more urgent. By dismantling the MPP, the Administration
    has directly caused a massive uptick in illegal immigration through Central America,
    Mexico, and to the U.S. southern border.
    6. MPP is an exercise of DHS’s express authority under the Immigration
    and Nationality Act, 8 U.S.C. § 1101 et seq., to return those aliens temporarily to
    Mexico during the pendency of their removal proceedings.
    See 8 U.S.C. § 1225(b)(2)(C). The Secretary of Homeland Security implemented MPP
    to manage the large influx of aliens arriving on the southern border with no lawful
    basis for admission. MPP proved to be enormously effective: it enabled DHS to avoid
    detaining or releasing into the United States more than 71,000 migrants during
    removal proceedings, and curtailed the number of aliens approaching or attempting
    to cross the southern border.1 The program served as an indispensable tool in the
    United States’ efforts, working cooperatively with the governments of Mexico and
    other countries, to address the migration crisis by diminishing incentives for illegal
    immigration, weakening cartels and human smugglers, and enabling DHS to better
    focus its resources on legitimate asylum claims.
    7. Nonetheless, the Biden Administration cast aside congressionally
    enacted immigration laws and suspended new enrollments in MPP on its first day in
    office. In a peremptory two-sentence, three-line memorandum, the Acting Secretary
    of Homeland Security issued a directive, effective January 21, 2021, that DHS would
    1 See, e.g., TRAC Immigration, Details on MPP (Remain in Mexico) Deportation
    Proceedings, https://trac.syr.edu/phptools/immigration/mpp/.
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 4 of 40 PageID 4
    5
    “suspend new enrollments in [MPP], pending further review of the program.” Exhibit
    A (“January 20 Memorandum”). This memorandum provided no analysis or reasoned
    justification for this abrupt suspension. In doing so, the Biden Administration
    ignored the governing legal authority and basic requirements set forth in the
    Administrative Procedure Act, 5 U.S.C. § 551 et seq., 5 U.S.C. § 701 et seq.
    8. The Biden Administration’s suspension “takes off the table one of the
    few congressionally authorized measures available to process” the vast numbers of
    migrants arriving at the southern border on a daily basis. Innovation L. Lab v.
    McAleenan, 924 F.3d 503, 510 (9th Cir. 2019) (per curiam). Before MPP, U.S. officials
    encountered an average of approximately 2,000 inadmissible aliens at the southern
    border each day, and the rate at which those aliens claimed fear of return to their
    home countries surged exponentially.
    9. That huge influx imposes enormous, avoidable burdens on the United
    States’ immigration system. Most asylum claims are meritless. For example, the
    Executive Office for Immigration Review (“EOIR”) reported that between FY 2008
    and FY 2019, only 14 percent of aliens who claimed credible fear were granted
    asylum.2 Alongside the fact that immigration courts were faced with a backlog of
    over 768,000 cases at the end of FY 2018—a number that since has grown—it is clear
    the asylum system was and continues to be manipulated by aliens presenting at the
    2 See Executive Office for Immigration Review Adjudication Statistics, Credible
    Fear and Asylum Process: Fiscal Year (FY) 2008 – FY 2019 (Oct. 23,
    2019), https://www.justice.gov/eoir/file/1216991/download.
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 5 of 40 PageID 5
    6
    border.3
    10. MPP played a critical role in addressing this crisis. By returning
    migrants to Mexico to await their asylum proceedings—in cooperation with the
    Mexican Government, which has permitted these aliens to remain in Mexico—MPP
    eased the strain on the United States’ immigration-detention system and reduced the
    ability of inadmissible aliens to abscond into the United States. Between FY 2008
    and FY 2019, 32 percent of aliens referred to EOIR absconded into the United States
    and were ordered removed in absentia.4
    11. MPP also discouraged aliens from attempting illegal entry or making
    meritless asylum claims in the hope of staying inside the United States, thereby
    permitting the government to better focus its resources on individuals who
    legitimately qualify for relief or protection from removal. In February 2020, for
    example, the number of aliens either apprehended or deemed inadmissible at the
    southern border was down roughly 40,000 from February 2019.5 The Biden
    Administration’s suspension of the MPP has imposed severe and ongoing burdens on
    Texas and Missouri because the government will not process into the MPP the tens
    of thousands of aliens who are resuming attempts to cross the southern border with
    no legal basis for admission, and the government will process the tens of thousands
    of aliens already admitted into the MPP into the United States.
    3 See TRAC Immigration, Immigration Court Backlog Tool,
    https://trac.syr.edu/phptools/immigration/court_backlog/.
    4 See Credible Fear and Asylum Process, supra, at n.2. 5 U.S. Customs & Border Protection, Southwest Border Migration FY 2020,
    https://go.usa.gov/xdhSh (last visited Apr. 9, 2020).
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 6 of 40 PageID 6
    7
    12. Additionally, the Biden Administration’s suspension threatens damage
    to the bilateral relationship between the United States and Mexico. Migration has
    been the subject of substantial discussion between the two countries and is a key topic
    of ongoing concern in their relationship.6 The unchecked flow of third-country
    migrants through Mexico to the United States strains both countries’ resources and
    produces significant public safety risks—not only to the citizens of Mexico and the
    United States, but also to the migrants themselves, who are often targeted by
    criminals for human trafficking, violence, and extortion. MPP played a key role in
    joint efforts to address the crisis, but the suspension of MPP upsets those efforts and
    undermines Mexican confidence in U.S. foreign policy commitments. And like Texas
    and Missouri, the Mexican government intends to “crack down on migrant
    trafficking.”7 But the suspension of MPP can only significantly delay those
    enforcement efforts given the constant flow of migrants.
    13. Texas contains more than half of the border between the United States
    and Mexico, and a large share of individuals crossing into the United States to claim
    asylum arrive through the Texas-Mexico border. Likewise, human traffickers and
    their victims frequently arrive in Texas and either settle there, travel to one of
    6 See, e.g., U.S. Department of Homeland Security, Assessment of the Migrant
    Protection Protocols (MPP) (Oct. 28, 2019),
    https://www.dhs.gov/sites/default/files/publications/assessment_of_the_migrant_pro
    tection_protocols_mpp.pdf; Declaration of Ambassador Christopher Landau, No. 19-
    15716, Doc. 92-3, ¶ 3 (9th Cir.).
    7 Mark Stevenson et al., Biden tries to reset relationship with Mexican
    president, ASSOCIATED PRESS (Mar. 1, 2021), https://apnews.com/article/bidenobrador-us-mexico-migration-issues-edb25cf298b7c9a83d15ff4f6c7ea95f.
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 7 of 40 PageID 7
    8
    Texas’s major cities, or travel along Texas’s state highways to proceed further into
    the United States.
    14. Missouri is a destination and transit state for many human traffickers,
    including human traffickers of migrants from Central American countries who have
    crossed the border illegally. This is mainly due to the state’s substantial
    transportation infrastructure and major population centers. Indeed, St. Louis and
    Kansas City are major human-trafficking hubs connected by Interstate 70.
    15. As a direct result of the suspension of new enrollments into the MPP,
    and the corresponding increase in human-trafficking incidents involving vulnerable
    Central American migrants, both Texas and Missouri will be forced to spend
    significantly more resources in combating human trafficking. Thus, the Biden
    Administration’s unlawful suspension of the MPP will cause both States immediate
    and irreparable harm if it is not enjoined.
    16. Moreover, the influx of unlawful immigrants with meritless claims of
    asylum will result in additional unlawful migrants entering and remaining in Texas
    and Missouri, thus forcing both States to expend more taxpayer resources on health
    care, education, social services, and similar services for such migrants. There is no
    monetary remedy for these increased costs and thus they constitute irreparable
    injury to the State of Texas, the State of Missouri, and their taxpayers.
    17. Because suspension of the MPP is invalid, it must be enjoined in its
    entirety. See, e.g., United Steel v. Mine Safety & Health Admin., 925 F.3d 1279, 1287
    (D.C. Cir. 2019) (“The ordinary practice is to vacate unlawful agency action.”); Nat’l
    Case 2:21-cv-00067-Z Document 1 Filed 04/13/21 Page 8 of 40 PageID 8
    9
    Min. Ass’n v. U.S. Army Corps of Engineers, 145 F.3d 1399, 1409 (D.C. Cir.
    1998) (unlawful agency regulations are vacated); Gen. Chem. Corp. v. United States,
    817 F.2d 844, 848 (D.C. Cir. 1987) (“The APA requires us to vacate the agency’s
    decision if it is ‘arbitrary, capricious, an abuse of discretion, or otherwise not in
    accordance with law[.]’ ”). Indeed, federal law contemplates a “comprehensive and
    unified” immigration policy. Arizona, 567 U.S. at 401. As the Fifth Circuit has held,
    “[t]he Constitution requires an uniform Rule of Naturalization; Congress has
    instructed that the immigration laws of the United States should be enforced
    vigorously and uniformly; and the Supreme Court has described immigration policy
    as a comprehensive and unified system.” Texas v. United States, 809 F.3d 134, 187–
    88 (5th Cir. 2015), aff’d, 136 S. Ct. 2271 (2016) (per curiam). Thus, “a fragmented
    immigration policy would run afoul of the constitutional and statutory requirement
    for uniform immigration law and policy.” Washington v. Trump, 847 F.3d 1151, 1166–
    67 (9th Cir. 2017) (per curiam); see also Texas v. United States, No. 6:21-CV-00003,
    2021 WL 247877, at *8 (S.D. Tex. Jan. 26, 2021) (enjoining government from
    executing 100-day moratorium on the removal of aliens everywhere in the United
    States).

    You May Also Be Interested In

    JW Grenadier v. Leon Cooperman, Glenn Messina, OCWEN, Judge Lawyer Donald R. Alexander Verified listing

    • In the Circuit Court of the Second Judicial Circuit Leon County, Florida
    • 2024-CA-00634
    • Rico Racketeering, Constitutional Rights, Foreclosure Fraud
    • Judge Angela C. Dempsey

    Virginia Judiciary Treason "OK" with JIRC Verified listing

    • JIRC Judicial Inquiry & Review Commission For Acts & Actions of SCV Chief Justices Bernard Goodwyn, Donald Lemons, Cynthia Kinser "Fixer" Judges in Richmond, City of Alexandria, Fairfax, Orange, Culpeper & Virginia Beach Virginia
    • Divorce, Constitutional, Civil Rights, "Fake" illegal Foreclosure, unlawful arrest & assaualt by a Sheriff,
    • Chief Justice Bernard Goodwyn, Chief Justice Donald Lemmons Chief Justice Cynthia Kinser

    SCOTUS Writ of Mandamus & Prohibition for Investigation into USDC of District of Columbia for Political & Religions BIAS by Judges et al Verified listing

    • The Supreme Court of the United States (SCOTUS)
    • No. 23-7758
    • Writ of Mandamus & Prohibition for Investigation of Political & Religious bias of the Judges
    • John G. Roberts, Jr., Chief Justice of the United States, ... Clarence Thomas, Associate Justice, ... Samuel A. Alito, Jr., Associate Justice, ... Sonia Sotomayor, Associate Justice, ... Elena Kagan, Associate Justice, ... Neil M. Gorsuch, Associate Justice, ... Brett M. Kavanaugh, Associate Justice, John G. Roberts, Chief Justice of the United States John G. Roberts, Jr., Chief Justice of the United States, was born in Buffalo, New York, January 27, 1955. He married Jane Sullivan in 1996 and they have two children - Josephine and Jack. He received an A.B. from Harvard College in 1976 and a J.D. from Harvard Law School in 1979. He served as a law clerk for Judge Henry J. Friendly of the United States Court of Appeals for the Second Circuit from 1979–1980, and as a law clerk for then-Associate Justice William H. Rehnquist of the Supreme Court of the United States during the 1980 Term. He served as a Special Assistant to the Attorney General of the United States from 1981–1982, Associate Counsel to President Ronald Reagan, White House Counsel’s Office from 1982–1986, and as Principal Deputy Solicitor General from 1989–1993. From 1986–1989 and 1993–2003, he practiced law in Washington, D.C. He served as a Judge on the Court of Appeals for the District of Columbia Circuit from 2003–2005. Nominated as Chief Justice of the United States by President George W. Bush, he assumed that office on September 29, 2005. Clarence Thomas, Associate Justice Clarence Thomas, Associate Justice, was born in the Pinpoint community near Savannah, Georgia on June 23, 1948. He attended Conception Seminary from 1967-1968 and received an A.B., cum laude, from College of the Holy Cross in 1971 and a J.D. from Yale Law School in 1974. He was admitted to law practice in Missouri in 1974, and served as an Assistant Attorney General of Missouri, 1974-1977; an attorney with the Monsanto Company, 1977-1979; and Legislative Assistant to Senator John Danforth, 1979-1981. From 1981–1982 he served as Assistant Secretary for Civil Rights, U.S. Department of Education, and as Chairman of the U.S. Equal Employment Opportunity Commission, 1982-1990. From 1990–1991, he served as a Judge on the United States Court of Appeals for the District of Columbia Circuit. President Bush nominated him as an Associate Justice of the Supreme Court and he took his seat October 23, 1991. He married Virginia Lamp on May 30, 1987 and has one child, Jamal Adeen by a previous marriage. Samuel A. Alito, Jr., Associate Justice Samuel A. Alito, Jr., Associate Justice, was born in Trenton, New Jersey, on April 1, 1950. He married Martha-Ann Bomgardner in 1985, and has two children - Philip and Laura. He served as a law clerk for Leonard I. Garth of the United States Court of Appeals for the Third Circuit from 1976–1977. He served as an Assistant U.S. Attorney, District of New Jersey, 1977–1981, as Assistant to the Solicitor General, U.S. Department of Justice, 1981–1985, as Deputy Assistant Attorney General, U.S. Department of Justice, 1985–1987, and as U.S. Attorney, District of New Jersey, 1987–1990. He was appointed to the United States Court of Appeals for the Third Circuit in 1990. President George W. Bush nominated him as an Associate Justice of the Supreme Court, and he took his seat January 31, 2006. Sonia Sotomayor, Associate Justice Sonia Sotomayor, Associate Justice, was born in Bronx, New York, on June 25, 1954. She earned a B.A. in 1976 from Princeton University, graduating summa cum laude and a member of Phi Beta Kappa and receiving the Pyne Prize, the highest academic honor Princeton awards to an undergraduate. In 1979, she earned a J.D. from Yale Law School where she served as an editor of the Yale Law Journal. She served as Assistant District Attorney in the New York County District Attorney’s Office from 1979–1984. She then litigated international commercial matters in New York City at Pavia & Harcourt, where she served as an associate and then partner from 1984–1992. In 1991, President George H.W. Bush nominated her to the U.S. District Court, Southern District of New York, and she served in that role from 1992–1998. In 1997, she was nominated by President Bill Clinton to the U.S. Court of Appeals for the Second Circuit where she served from 1998–2009. President Barack Obama nominated her as an Associate Justice of the Supreme Court on May 26, 2009, and she assumed this role August 8, 2009. Elena Kagan, Associate Justice Elena Kagan, Associate Justice, was born in New York, New York, on April 28, 1960. She received an A.B. from Princeton in 1981, an M. Phil. from Oxford in 1983, and a J.D. from Harvard Law School in 1986. She clerked for Judge Abner Mikva of the U.S. Court of Appeals for the D.C. Circuit from 1986-1987 and for Justice Thurgood Marshall of the U.S. Supreme Court during the 1987 Term. After briefly practicing law at a Washington, D.C. law firm, she became a law professor, first at the University of Chicago Law School and later at Harvard Law School. She also served for four years in the Clinton Administration, as Associate Counsel to the President and then as Deputy Assistant to the President for Domestic Policy. Between 2003 and 2009, she served as the Dean of Harvard Law School. In 2009, President Obama nominated her as the Solicitor General of the United States. A year later, the President nominated her as an Associate Justice of the Supreme Court on May 10, 2010. She took her seat on August 7, 2010. Neil M. Gorsuch, Associate Justice Neil M. Gorsuch, Associate Justice, was born in Denver, Colorado, August 29, 1967. He and his wife Louise have two daughters. He received a B.A. from Columbia University, a J.D. from Harvard Law School, and a D.Phil. from Oxford University. He served as a law clerk to Judge David B. Sentelle of the United States Court of Appeals for the District of Columbia Circuit, and as a law clerk to Justice Byron White and Justice Anthony M. Kennedy of the Supreme Court of the United States. From 1995–2005, he was in private practice, and from 2005–2006 he was Principal Deputy Associate Attorney General at the U.S. Department of Justice. He was appointed to the United States Court of Appeals for the Tenth Circuit in 2006. He served on the Standing Committee on Rules for Practice and Procedure of the U.S. Judicial Conference, and as chairman of the Advisory Committee on Rules of Appellate Procedure. He taught at the University of Colorado Law School. President Donald J. Trump nominated him as an Associate Justice of the Supreme Court, and he took his seat on April 10, 2017. Brett M. Kavanaugh, Associate Justice Brett M. Kavanaugh, Associate Justice, was born in Washington, D.C., on February 12, 1965. He married Ashley Estes in 2004, and they have two daughters - Margaret and Liza. He received a B.A. from Yale College in 1987 and a J.D. from Yale Law School in 1990. He served as a law clerk for Judge Walter Stapleton of the U.S. Court of Appeals for the Third Circuit from 1990-1991, for Judge Alex Kozinski of the U.S. Court of Appeals for the Ninth Circuit from 1991-1992, and for Justice Anthony M. Kennedy of the U.S. Supreme Court during the 1993 Term. In 1992-1993, he was an attorney in the Office of the Solicitor General of the United States. From 1994 to 1997 and for a period in 1998, he was Associate Counsel in the Office of Independent Counsel. He was a partner at a Washington, D.C., law firm from 1997 to 1998 and again from 1999 to 2001. From 2001 to 2003, he was Associate Counsel and then Senior Associate Counsel to President George W. Bush. From 2003 to 2006, he was Assistant to the President and Staff Secretary for President Bush. He was appointed a Judge of the United States Court of Appeals for the District of Columbia Circuit in 2006. President Donald J. Trump nominated him as an Associate Justice of the Supreme Court, and he took his seat on October 6, 2018. Amy Coney Barrett, Associate Justice Amy Coney Barrett, Associate Justice, was born in New Orleans, Louisiana, on January 28, 1972. She married Jesse M. Barrett in 1999, and they have seven children - Emma, Vivian, Tess, John Peter, Liam, Juliet, and Benjamin. She received a B.A. from Rhodes College in 1994 and a J.D. from Notre Dame Law School in 1997. She served as a law clerk for Judge Laurence H. Silberman of the U.S. Court of Appeals for the D.C. Circuit from 1997 to 1998, and for Justice Antonin Scalia of the Supreme Court of the United States during the 1998 Term. After two years in private law practice in Washington, D.C., she became a law professor, joining the faculty of Notre Dame Law School in 2002. She was appointed a Judge of the United States Court of Appeals for the Seventh Circuit in 2017. President Donald J. Trump nominated her as an Associate Justice of the Supreme Court, and she took her seat on October 27, 2020. Ketanji Brown Jackson, Associate Justice Ketanji Brown Jackson, Associate Justice, was born in Washington, D.C., on September 14, 1970. She married Patrick Jackson in 1996, and they have two daughters. She received an A.B., magna cum laude, from Harvard-Radcliffe College in 1992, and a J.D., cum laude, from Harvard Law School in 1996. She served as a law clerk for Judge Patti B. Saris of the U.S. District Court for the District of Massachusetts from 1996 to 1997, Judge Bruce M. Selya of the U.S. Court of Appeals for the First Circuit from 1997 to 1998, and Justice Stephen G. Breyer of the Supreme Court of the United States during the 1999 Term. After three years in private practice, she worked as an attorney at the U.S. Sentencing Commission from 2003 to 2005. From 2005 to 2007, she served as an assistant federal public defender in Washington, D.C., and from 2007 to 2010, she was in private practice. She served as a Vice Chair and Commissioner on the U.S. Sentencing Commission from 2010 to 2014. In 2012, President Barack Obama nominated her to the U.S. District Court for the District of Columbia, where she served from 2013 to 2021. She was appointed to the Defender Services Committee of the Judicial Conference of the United States in 2017, and the Supreme Court Fellows Commission in 2019. President Joseph R. Biden, Jr., appointed her to the United States Court of Appeals for the District of Columbia Circuit in 2021 and then nominated her as an Associate Justice of the Supreme Court in 2022. She took her seat on June 30, 2022. Anthony M. Kennedy, Associate Justice Anthony M. Kennedy (Retired), Associate Justice, was born in Sacramento, California, July 23, 1936. He married Mary Davis and has three children. He received his B.A. from Stanford University and the London School of Economics, and his LL.B. from Harvard Law School. He was in private practice in San Francisco, California from 1961–1963, as well as in Sacramento, California from 1963–1975. From 1965 to 1988, he was a Professor of Constitutional Law at the McGeorge School of Law, University of the Pacific. He has served in numerous positions during his career, including a member of the California Army National Guard in 1961, the board of the Federal Judicial Center from 1987–1988, and two committees of the Judicial Conference of the United States: the Advisory Panel on Financial Disclosure Reports and Judicial Activities, subsequently renamed the Advisory Committee on Codes of Conduct, from 1979–1987, and the Committee on Pacific Territories from 1979–1990, which he chaired from 1982–1990. He was appointed to the United States Court of Appeals for the Ninth Circuit in 1975. President Reagan nominated him as an Associate Justice of the Supreme Court, and he took his seat February 18, 1988. Justice Kennedy retired from the Supreme Court on July 31, 2018. David Hackett Souter, Associate Justice David H. Souter (Retired), Associate Justice, was born in Melrose, Massachusetts, September 17, 1939. He graduated from Harvard College, from which he received his A.B. After two years as a Rhodes Scholar at Magdalen College, Oxford, he received an A.B. in Jurisprudence from Oxford University and an M.A. in 1963. After receiving an LL.B. from Harvard Law School, he was an associate at Orr and Reno in Concord, New Hampshire from 1966 to 1968, when he became an Assistant Attorney General of New Hampshire. In 1971, he became Deputy Attorney General and in 1976, Attorney General of New Hampshire. In 1978, he was named an Associate Justice of the Superior Court of New Hampshire, and was appointed to the Supreme Court of New Hampshire as an Associate Justice in 1983. He became a Judge of the United States Court of Appeals for the First Circuit on May 25, 1990. President Bush nominated him as an Associate Justice of the Supreme Court, and he took his seat October 9, 1990. Justice Souter retired from the Supreme Court on June 29, 2009. Stephen G. Breyer, Associate Justice Stephen G. Breyer (Retired), Associate Justice, was born in San Francisco, California, August 15, 1938. He married Joanna Hare in 1967, and has three children - Chloe, Nell, and Michael. He received an A.B. from Stanford University, a B.A. from Magdalen College, Oxford, and an LL.B. from Harvard Law School. He served as a law clerk to Justice Arthur Goldberg of the Supreme Court of the United States during the 1964 Term, as a Special Assistant to the Assistant U.S. Attorney General for Antitrust, 1965–1967, as an Assistant Special Prosecutor of the Watergate Special Prosecution Force, 1973, as Special Counsel of the U.S. Senate Judiciary Committee, 1974–1975, and as Chief Counsel of the committee, 1979–1980. He was an Assistant Professor, Professor of Law, and Lecturer at Harvard Law School, 1967–1994, a Professor at the Harvard University Kennedy School of Government, 1977–1980, and a Visiting Professor at the College of Law, Sydney, Australia and at the University of Rome. From 1980–1990, he served as a Judge of the United States Court of Appeals for the First Circuit, and as its Chief Judge, 1990–1994. He also served as a member of the Judicial Conference of the United States, 1990–1994, and of the United States Sentencing Commission, 1985–1989. President Clinton nominated him as an Associate Justice of the Supreme Court, and he took his seat August 3, 1994. Justice Breyer retired from the Supreme Court on June 30, 2022
    Liberty Bell

    The Liberty Bell reads:

    "Proclaim Liberty throughout the land unto all the inhabitants thereof." -Leviticus 25:10.

    Let us continue to ring the bell for Justice!

     

    Judicialpedia follows The Constitution of the United States of America which is the Supreme Law of the United States. The First Amendment: Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.

     

    Judicialpedia gives every American a place to exercise The First Amendment. When you post and submit a case you agree to the following: When this form is submitted, the party giving the written statement declares the facts / information stated are true and confirms this to the best of their knowledge. The party confirms that the information here is both accurate and that relevant information has not been omitted.

    Follow Us on FacebookFollow Us on TwitterFollow Us on InstagramFollow Us on Blogger
    Donate to Judicialpedia
    Add a Case or Complaint
    • Copyright and Trademark Judicialpedia 2020-2023.
    • All Rights Reserved.
    • Terms of Use
    • Contact Us

    Cart

      • Facebook
      • Twitter
      • WhatsApp
      • Telegram
      • LinkedIn
      • Tumblr
      • VKontakte
      • Mail
      • Copy link