Department of Labor and Industries v. Geo Secure Services LLC

CourtDistrict Court, W.D. Washington
DecidedJuly 1, 2024
Docket3:24-cv-05095
StatusUnknown

This text of Department of Labor and Industries v. Geo Secure Services LLC (Department of Labor and Industries v. Geo Secure Services LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Department of Labor and Industries v. Geo Secure Services LLC, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 DEPARTMENT OF LABOR AND CASE NO. C24-5095 BHS 8 INDUSTRIES OF THE STATE OF WASHINGTON, ORDER 9 Plaintiff, 10 v. 11 GEO SECURE SERVICES, LLC; THE GEO GROUP, INC., 12 Defendant. 13

14 This matter is before the Court the Washington Department of Labor and 15 Industries (L&I)’s motions to remand this matter to the Pierce County Superior Court, 16 Dkt. 10; to consolidate this matter with State of Washington Dep’t of Health v. The GEO 17 Group, Inc., No. C24-5029 BHS, Dkt. 18; and to preliminary enjoin GEO1 from denying 18 the agency access to inspect the Northwest ICE2 Processing Center (the NWIPC)—the 19 sole immigration detention facility in Washington which GEO operates pursuant to a 20

21 1 The defendants in this matter are both GEO Secure Services, LLC, and the GEO Group, Inc. Dkt. 15, ¶¶ 2, 3. For simplicity, the Court refers to them collectively as “GEO.” 22 2 Immigration and Customs Enforcement. 1 contract with ICE, Dkt. 23. L&I seeks such an injunction pursuant to both HB 1470 § 33 2 (a law requiring L&I to “conduct routine, unannounced inspections of workplace

3 conditions at private detention facilities, including work undertaken by detained 4 persons”) and RCW 49.17.070 (a statute authorizing L&I to inspect conditions at 5 worksites generally). 6 GEO removed the action to this Court under the “federal officer” removal statute, 7 28 U.S.C. §1442(a)(1). This statute generally provides that any person acting under an 8 officer or agency of the United States may remove an action to federal court when that

9 person can assert a “colorable federal defense.” Jefferson County v. Acker, 527 U.S. 423, 10 431 (1999). 11 GEO asserts a colorable federal defense to L&I’s efforts to inspect the NWIPC 12 under HB 1470 § 3. In a recent order in a related case, this Court ruled that HB 1470 § 3 13 is unconstitutional as applied to GEO as the operator of the NWIPC. See The GEO

14 Group, Inc. v. Inslee, ___ F. Supp. 3d ___, No. C23-5626 BHS, 2024 WL 1012888, at 15 *24–26 (W.D. Wash. Mar. 8, 2024). The Court explained that HB 1470 “was designed to 16 apply to only the NWIPC and any other private immigration detention facility that may 17 eventually exist in Washington” and that “§ 3 discriminates against [GEO] in violation of 18 the intergovernmental immunity doctrine.” Id. at *16, 26. The Court preliminarily

19 enjoined the State and its agencies, including L&I, from enforcing HB 1470 § 3 against 20 GEO. Id. at *30. L&I’s motion to remand is accordingly denied. 21

22 3 HB 1470 § 3 is codified as RCW 70.395.050. 1 The Court also declines to consolidate this case with State of Washington Dep’t of 2 Health, No. C24-5029 BHS. Because L&I is not entitled to inspect the NWIPC under HB

3 1470 § 3, the primary remaining issue in this case is whether it is entitled to do so under 4 RCW 49.17.070. This statute authorizes L&I to conduct reasonable inspections of any 5 workplace under certain circumstances. By contrast, the primary issue in State of 6 Washington Dep’t of Health, No. C24-5029 BHS, is whether the Washington Department 7 of Health (DOH) is entitled to inspect the NWIPC under an entirely different statute, 8 RCW 43.70.170. That statute authorizes DOH to inspect any condition constituting a

9 threat to the public health. These cases concern different statutes and, in turn, involve 10 different questions of law and fact. The motion to consolidate is denied. 11 To the extent L&I seeks an injunction under HB 1470 § 3, such relief is plainly 12 foreclosed by the Court’s order declaring that law to be unconstitutional as applied to 13 GEO. See Inslee, ___ F. Supp. 3d ___, 2024 WL 1012888, at *24–26. However, to the

14 extent L&I seeks a preliminary injunction under RCW 49.17.070, it demonstrates an 15 entitlement to such relief. This statute is a generally applicable safety and health law and, 16 therefore, it does not suffer from the same constitutional deficiency as HB 1470 § 3. 17 The Court also rejects GEO’s assertion that it is entitled to “derivative sovereign 18 immunity” against L&I’s claim under RCW 49.17.070. That immunity generally

19 provides federal contractors a defense to liability when the contractor’s actions are both 20 authorized and directed by a government official and performed pursuant to an Act of 21 Congress. Because GEO does not identify any federal law prohibiting state legislatures 22 from imposing generally applicable safety and health laws like RCW 49.17.070 on 1 private immigration detention facilities, it is not immune from L&I’s claim under this 2 statute. L&I’s motion for a preliminary injunction is accordingly granted in part and

3 denied in part. 4 I. BACKGROUND 5 In 2023, the Washington legislature enacted HB 1470, which amended chapter 6 70.395 RCW to impose numerous requirements on “private detention facilities.” 7 Following the passage of this law, GEO sued Washington’s governor, Jay Inslee, and 8 attorney general, Robert Ferguson, in a different case before this Court, seeking to enjoin

9 the enforcement of HB 1470 against it as the operator of the NWIPC. See Dkt. 1 in 10 Inslee, No. C23-5626 BHS. GEO claimed, among other things, that HB 1470 is 11 unconstitutional as applied to it because the law impermissibly discriminates against it in 12 violation of the Supremacy Clause’s intergovernmental immunity doctrine. Id. ¶¶ 74–83. 13 After GEO filed that lawsuit, two L&I officials attempted to inspect the NWIPC

14 on two occasions in December 2023. On December 27, they visited the NWIPC and 15 attempted to inspect workplace conditions at the facility pursuant to HB 1470 § 3. Dkt. 16 27-5 at 4. The officials explained to the NWIPC’s facility administrator, Bruce Scott, that 17 they were “[t]here to open a comprehensive workplace safety and health inspection.” Id. 18 Scott explained that he had to make a telephone call “before he [gave] [them]

19 permission” to enter the facility. Id. Scott left the lobby area and, shortly thereafter, 20 returned and told the L&I officials that “ICE has directed us to not allow you entry 21 today.” Id. Scott accordingly denied the L&I officials access to the NWIPC. See id. 22 1 These L&I officials subsequently applied for—and obtained—a search warrant 2 from the Pierce County Superior Court to inspect the NWIPC under both HB 1470 § 3

3 and RCW 49.17.070. Dkt. 27-4 at 2. The warrant compelled GEO to provide L&I access 4 to the NWIPC “to allow the conducting therein of a safety and health inspection for the 5 purpose of ascertaining and causing to be corrected any conditions presenting safety or 6 health hazards to employees of GEO . . . under chapter 49.17 [RCW], chapter 70.395 7 RCW and Title 296 [WAC].” Dkt. 27-6 at 3.

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Bluebook (online)
Department of Labor and Industries v. Geo Secure Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/department-of-labor-and-industries-v-geo-secure-services-llc-wawd-2024.