ROBERT A. NOLAN v. GURBIR S. GREWAL (DIVISION OF CRIMINAL JUSTICE)

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 26, 2022
DocketA-4614-19
StatusUnpublished

This text of ROBERT A. NOLAN v. GURBIR S. GREWAL (DIVISION OF CRIMINAL JUSTICE) (ROBERT A. NOLAN v. GURBIR S. GREWAL (DIVISION OF CRIMINAL JUSTICE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ROBERT A. NOLAN v. GURBIR S. GREWAL (DIVISION OF CRIMINAL JUSTICE), (N.J. Ct. App. 2022).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4614-19

ROBERT A. NOLAN, in his official capacity as CAPE MAY COUNTY SHERIFF, and COUNTY OF CAPE MAY,

Plaintiffs-Appellants,

v.

GURBIR S. GREWAL, in his official capacity as ATTORNEY GENERAL OF THE STATE OF NEW JERSEY, and OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LAW AND PUBLIC SAFETY, DIVISION OF CRIMINAL JUSTICE, 1

Defendants-Respondents. _____________________________

Submitted November 4, 2021 – Decided January 26, 2022

Before Judges Hoffman, Whipple, and Susswein.

1 The caption in the parties' briefs incorrectly designates the Office of the Attorney General as the "Office of the State of New Jersey." On appeal from the Office of the Attorney General, Department of Law and Public Safety, Division of Criminal Justice.

Jeffrey R. Lindsay, Cape May County Counsel, attorney for appellants (Jeffrey R. Lindsay, on the briefs).

Andrew J. Bruck, Acting Attorney General, attorney for respondents (Jeremy Feigenbaum, State Solicitor, and Jane C. Schuster, Assistant Attorney General, of counsel and on the brief; Emily Marie Bisnauth, Marie Soueid, Emily Wanger, and Sean P. Havern, Deputy Attorneys General, on the brief).

PER CURIAM

Robert Nolan, in his official capacity as Cape May County Sheriff, and

the County of Cape May (appellants) filed this action with this court on August

28, 2020, seeking a judgment declaring invalid and unenforceable Attorney

General Law Enforcement Directive No. 2018-6 v2.0, also known as the

Immigrant Trust Directive (Directive 2018-6 v2.0 or the Directive). The

Attorney General issued the Directive, which places strict limitations on state,

local, and county law enforcement agencies regarding their participation in the

enforcement of federal immigration law, with the goal of improving public trust

and clarifying the distinct roles of federal and state actors.

Appellants contend the Attorney General's issuance of the Directive,

without complying with the New Jersey Administrative Procedure Act (APA),

A-4614-19 2 N.J.S.A. 52:14B-1 to -31, renders it invalid and unenforceable. We disagree,

concluding that the Directive falls under the statutory exemptions for inter-

agency and intra-agency communications, as well as the statutory exemption for

statements concerning the internal management of an agency. N.J.S.A. 52:14B–

2. We therefore affirm the action of the Attorney General's issuance of Directive

2018-6 v2.0.

I.

We begin with a review of immigration law and prior Directives issued by

the Attorney General regarding the participation of state, local, and county law

enforcement agencies in the enforcement of federal immigration law.

A. Background on Immigration Law

Under our federal system, the federal government "has broad, undoubted

power over the subject of immigration and the status of aliens," Arizona v.

United States, 567 U.S. 387, 394 (2012), while the "States possess primary

authority for defining and enforcing the criminal law." United States v. Lopez,

514 U.S. 549, 561 n.3 (1995). Pursuant to the federal government's authority in

this area, the Immigration and Nationality Act (INA), 8 U.S.C. §§ 1101 to 1537,

"establishe[s] a 'comprehensive federal statutory scheme for regulation o f

immigration and naturalization.'" Chamber of Com. of U.S. v. Whiting, 563

A-4614-19 3 U.S. 582, 587 (2011) (quoting De Canas v. Bica, 424 U.S. 351, 353 (1976)).

This includes regulation of "which aliens may be removed from the United

States and the procedures for doing so." Arizona, 567 U.S. at 396. "Agencies

in the Department of Homeland Security[,]" including Immigration and Customs

Enforcement (ICE), "play a major role in enforcing" the INA. Id. at 397. ICE

is responsible both for "conduct[ing] criminal investigations involving the

enforcement of immigration-related statutes" and "for the identification,

apprehension, and removal of illegal aliens from the United States." Ibid.

"Removal is a civil, not criminal, matter[,]" over which federal immigration

officials exercise "broad discretion." Id. at 396.

However, "[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." Id. at 397. The powers of the federal

government to regulate immigration, and the State, to regulate criminal conduct,

"intersect when a state or city arrests an individual whom ICE would also like

to apprehend for removal proceedings." City of Phila. v. Att'y Gen. of the U.S.,

916 F.3d 276, 281 (3d Cir. 2019). "Consultation between federal and state

officials is an important feature of the immigration system." Arizona, 567 U.S.

at 411. Various provisions of the INA "specif[y] limited circumstances in which

A-4614-19 4 state officers may perform the functions of an immigration officer. A principal

example is when the [United States] Attorney General has [pursuant to Section

287(g) of the INA] granted that authority to specific officers in a formal

agreement with a state or local government." Id. at 408 (citing 8 U.S.C. §

1357(g)(1)). These agreements allow state, county, or local law enforcement

officers to perform the "function[s] of an immigration officer in relation to the

investigation, apprehension, or detention of aliens . . . at the expense of the State

or political subdivision[,]" but under the direction and supervision of the United

States Attorney General. 8 U.S.C. § 1357(g)(1) to (3).

Section 287(g) makes clear that it does not require states and localities to

enter into these agreements. 8 U.S.C. § 1357(g)(9). Where such agreements

exist, state law enforcement officers may operate under them only "to the extent

consistent with State and local law." 8 U.S.C. § 1357(g)(1). Other forms of

cooperation contemplated by the INA are also generally voluntary on the part of

states and localities. For example, the INA refers to detainer requests, 8 U.S.C.

§ 1357(d), but "does not authorize federal officials to command state or local

officials to detain suspected aliens subject to removal" nor to command "notice

of a prisoner's release." Galarza v. Szalczyk, 745 F.3d 634, 641 (3d Cir. 2014).

A-4614-19 5 In short, while state and federal cooperation is important to the

immigration system that Congress has put in place, that system ultimately

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