The GEO Group Inc v. Inslee

CourtDistrict Court, W.D. Washington
DecidedMarch 8, 2024
Docket3:23-cv-05626
StatusUnknown

This text of The GEO Group Inc v. Inslee (The GEO Group Inc v. Inslee) 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
The GEO Group Inc v. Inslee, (W.D. Wash. 2024).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 THE GEO GROUP, INC., CASE NO. C23-5626 BHS 8 Plaintiff, ORDER 9 v. 10 JAY R. INSLEE, in his official capacity as the Governor of the State of 11 Washington; and ROBERT W. FERGUSON, in his official capacity as 12 Attorney General of the State of Washington. 13 Defendants. 14

15 This matter is before the Court on the GEO Group, Inc.’s motion for a preliminary 16 injunction, Dkt. 8, and the State of Washington’s1 motion to dismiss under Federal Rules 17 of Civil Procedure 12(b)(1) and 12(b)(6), Dkt. 17. 18 In 2023, the Washington legislature enacted House Bill (HB) 1470, which imposes 19 numerous requirements on private detention facilities within the State. Although HB 20

21 1 The defendants in this matter are Washington’s Governor, Jay Inslee, and its Attorney General, Bob Ferguson. Each is sued in his official capacity. Dkt. 1, ¶ 1. For simplicity, the 22 Court refers to these defendants collectively as “the State.” 1 1470 defines “private detention facility” broadly, its history and text make clear that it 2 applies to only the Northwest ICE2 Processing Center (NWIPC)—the sole immigration

3 detention facility in Washington. GEO, which contracts with ICE to operate the NWIPC, 4 claims that HB 1470 violates the Supremacy Clause and Contract Clause of the United 5 States Constitution. 6 The primary issue in this case is whether HB 1470 violates the Supremacy Clause 7 by imposing additional burdens exclusively on GEO as the operator of an immigration 8 detention facility. The Supremacy Clause prohibits such discriminatory regulation, and

9 instead requires state laws that regulate federal contractors to be applied equally on 10 similarly situated constituents of the State. 11 Most of GEO’s arguments are directed at HB 1470 § 4, which imposes numerous 12 requirements on the conditions of confinement at private detention facilities. This section 13 prohibits the use of solitary confinement; requires an immediate response to sexual

14 violence and harassment grievances by “culturally competent professionals”; mandates 15 that mental health evaluations occur weekly; requires that each sleeping room have 16 access to windows, natural light, and natural air circulation; and mandates, at no cost to 17 detainees, access to televisions, telecommunications services, handheld radios, 18 computers, and internet.

19 HB 1470 § 4 does not apply to private detention facilities that operate pursuant to 20 a contract that was in effect prior to January 1, 2023. GEO and ICE last modified their 21

22 2 Immigration and Customs Enforcement. 1 contract before that date; they agreed in January 2021 for their contract to run through 2 September 2025. Therefore, HB 1470 § 4 does not currently apply to the NWIPC. And it

3 may never. GEO fails to establish that ICE will extend its contract for GEO to operate the 4 NWIPC beyond September 2025. GEO also fails to establish what the terms of any such 5 hypothetical contract would be. The Court is therefore unable to discern whether HB 6 1470 § 4 will ever be enforced against GEO as the operator of the NWIPC. GEO’s 7 challenges to HB 1470 § 4 are, in turn, not constitutionally ripe and the Court lacks 8 subject-matter jurisdiction to consider them.

9 The Court does, however, have subject-matter jurisdiction to consider GEO’s 10 constitutional challenges to Sections 2, 3, 5, and 6 of HB 1470. These sections impose 11 various burdens on the NWIPC that do not apply to any similarly situated facility in the 12 State. For instance, HB 1470 § 2 requires the Washington Department of Health (DOH) 13 to adopt various rules to ensure that private detention facilities comply with measurable

14 standards providing, sanitary, hygienic, and safe conditions to detained persons. It also 15 authorizes the Washington attorney general to enforce violations of these rules. 16 The State claims that HB 1470 § 2 does not impermissibly discriminate against 17 GEO in violation of the Supremacy Clause because it simply replicates standards that 18 already apply to residential treatment facilities. The Court disagrees. The Supremacy

19 Clause requires federal contractors to be treated the same as similarly situated 20 constituents of the State. Because residential treatment facilities are not sufficiently 21 similar to private immigration detention facilities like the NWIPC, HB 1470 § 2 22 impermissibly discriminates against GEO in violation of the Supremacy Clause. 1 HB 1470 § 3 requires DOH and the Department of Labor & Industries (L&I) to 2 conduct routine, unannounced inspections of private detention facilities. It also requires

3 DOH to adopt rules to ensure that private detention facilities allow for regular inspections 4 and comply with standards providing for sanitary, hygienic, and safe conditions of 5 confinement. It finally authorizes the Washington attorney general to enforce violations 6 of the rules adopted by DOH. Because the State fails to identify any other state law that 7 imposes burdens of this sort on similarly situated facilities, HB 1470 § 3 also 8 impermissibly discriminates against GEO in violation of the Supremacy Clause.

9 Finally, HB 1470 §§ 5, 6 subject the NWIPC to substantial economic burdens for 10 failing to comply with HB 1470’s mandates. Section 5 creates a private right of action for 11 detained persons aggrieved by violations of HB 1470, authorizing them to recover at least 12 $1,000 per violation against any person who negligently violates this law, and at least 13 $10,000 per violation against any person who intentionally or recklessly violates this law.

14 It also authorizes detained persons to recover reasonable attorney fees and costs and to 15 obtain other appropriate relief, including injunctive relief. Section 6 authorizes DOH to 16 impose civil penalties on the operators of private detention facilities who fail to comply 17 with HB 1470 in the amount of $1,000 per violation per day. It also authorizes the 18 Washington attorney general to bring an action to recover any civil penalties that are not

19 paid to DOH within 15 days of receipt of notice of the penalty. 20 The State again fails to identify any other state laws that impose burdens of this 21 sort on facilities that are similarly situated to the NWIPC. Accordingly, HB 1470 §§ 5, 6 22 also impermissibly discriminate against GEO in violation of the Supremacy Clause. 1 Because GEO sufficiently establishes that Sections 2, 3, 5, and 6 of HB 1470 2 impermissibly discriminate against it in violation of the Supremacy Clause, GEO is

3 entitled to an order preliminarily enjoining the enforcement of these sections against it as 4 the operator of the NWIPC. To the extent GEO claims that any of these sections violate 5 the Constitution in any other manner, those claims are not plausible and they are 6 dismissed with prejudice. 7 I. BACKGROUND 8 “The Government of the United States has broad, undoubted power over the

9 subject of immigration and the status of aliens.” Arizona v. United States (Arizona II), 10 567 U.S. 387, 394 (2012); see also U.S. CONST. art I, § 8, cl. 4 (granting Congress the 11 power to “establish an uniform Rule of Naturalization”). “Congress exercises its authority 12 to regulate the entry, presence, and removal of noncitizens through the Immigration and 13 Nationality Act (INA) and other related laws, and ‘has specified which aliens may be

14 removed from the United States and the procedures for doing so.’” United States v. 15 California, 921 F.3d 865, 973 (9th Cir. 2019) (quoting Arizona II, 567 U.S. at 396).

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