United States v. State of Alabama

443 F. App'x 411
CourtCourt of Appeals for the Eleventh Circuit
DecidedOctober 14, 2011
Docket11-14532-CC, 11-14535-CC
StatusUnpublished
Cited by5 cases

This text of 443 F. App'x 411 (United States v. State of Alabama) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. State of Alabama, 443 F. App'x 411 (11th Cir. 2011).

Opinions

PER CURIAM.

These two appeals involve the United States’ and various plaintiffs’1 (the “private plaintiffs”) challenges to the Beason-Hammon Alabama Taxpayer and Citizen Protection Act, Ala. Laws Act 2011-535 (“H.B.56”). In the district court, the United States and the private plaintiffs filed motions for a preliminary injunction as to various sections of H.B. 56. After a hearing, the district court granted the motions as to numerous sections of H.B. 56 but denied them as to other sections. Pursuant to Rules 8(a) and 27 of the Federal Rules of Appellate Procedure, the United States and the private plaintiffs move this Court to enjoin pending appeal Alabama’s enforcement of six of the sections of H.B. 56 not enjoined by the district court. After review and briefing, we grant in part and deny in part the motions for injunctions pending appeal.

I. PROCEDURAL BACKGROUND

On June 2, 2011, the Alabama Legislature approved H.B. 56, and Governor Robert Bentley signed H.B. 56 into law on June 9, 2011. The majority of the provisions in H.B. 56 were set to become effective on September 1, 2011.

A. United States’ Lawsuit

Seeking to permanently enjoin enforcement of certain provisions of H.B. 56, the United States sued the State of Alabama, Governor Robert J. Bentley in his official capacity, the National Fair Housing Alliance, Inc., and the American Unity Legal Defense Fund. The United States argued, inter alia, that Sections 10, 11(a), 12, 13, 16, 17, 18, 27, 28, and 30 of H.B. 56 were preempted under the Supremacy Clause and by federal law, principally the comprehensive registration scheme embodied in the Immigration and Nationality Act (“INA”), 8 U.S.C. § 1101, et seq.

The contents of the sections challenged by the United States are summarized as follows:

Section 10 creates a criminal misdemeanor violation under Alabama law for “willful failure to complete or carry an alien registration document if the person is in violation of 8 U.S.C. § 1304(e) or 8 [415]*415U.S.C. § 1806(a),2 and the person is an alien unlawfully present in the United States.” Section 10(b) prohibits law enforcement officers from attempting to independently make a final determination of whether an alien is lawfully present in the United States and requires law enforcement to determine immigration status by seeking verification from the federal government under 8 U.S.C. § 1373(c).3
Section 11(a) makes it a misdemeanor crime for an unauthorized alien to apply for, solicit, or perform work.
Section 12 requires a law enforcement officer — upon making “any lawful stop, detention, or arrest” in the enforcement of state or local law and upon reasonable suspicion that person stopped, detained, or arrested is unlawfully present in the United States — to make a reasonable attempt, “when practicable,” to determine the citizenship and immigration status of the person stopped, detained, or arrested, except if the determination may hinder or obstruct an investigation. A person is presumed not to be an alien who is unlawfully present if the alien presents a valid driver’s license, a valid Alabama non-driver identification card, an unexpired, government-issued identification bearing a photograph or other biometric identifier, a tribal identification card, or a foreign passport with an unexpired visa. A law enforcement officer may not consider race, color, or national origin in implementing this section. Section 12(b) requires law enforcement, within 24 hours of arresting an alien, to verify with the federal government the immigration status of the arrestee. If the federal verification “is delayed beyond the time that the alien would otherwise be released from custody, the alien shall be released from custody.” Section 13 makes it unlawful for a person to (1) conceal, harbor, or shield an alien unlawfully present in the United States, or attempt or conspire to do so; (2) encourage an unlawful alien to come to the State of Alabama; or (3) transport (or attempt or conspire to transport) an unlawful alien.
Section 16 forbids employers from claiming as business tax deductions any wages paid to an unauthorized alien.
Section 17 establishes a civil cause of action against an employer who fails to hire or discharges a U.S. citizen or an alien who is authorized to work while hiring or retaining an unauthorized alien.
Section 18 amends Ala.Code 32-6-9 to include a provision that if a person is arrested for driving without a license, and the officer is unable to determine by any other means that the person has a valid driver’s license, the officer shall transport the arrested person to the [416]*416nearest magistrate; a reasonable effort must be made to determine the citizenship of the arrested person, and if found to be unlawfully present in the United States, the arrested person shall be considered a flight risk and must be detained until prosecution or until handed over to federal immigration authorities. Section 27 bars Alabama courts from enforcing a contract to which a person who is unlawfully present in the United States is a party, if the party had direct or constructive knowledge that the alien was unlawfully present in the United States at the time the contract was entered into. This section does not apply to contracts for lodging for one night, contracts for the purchase of food, contracts for medical services, contracts for transportation for an alien to return to his or her country of origin, or any “contract authorized by federal law.” In court proceedings, the determination of whether an alien is unlawfully present in the United States shall be made by the federal government, pursuant to 8 U.S.C. § 1373(c).
Section 28 requires every public elementary and secondary school in Alabama, “at the time of enrollment in kindergarten or any grade in such school,” to determine if the student “was born outside the jurisdiction of the United States or is the child” of an unlawfully present alien and qualifies for assignment to an English as second language class or other remedial program. Section 28(a)(2) provides that, in making the above determination, the school “shall rely upon presentation of the student’s original birth certificate, or a certified copy thereof.” Section 28 also requires the school or district to compile the data required by the Section and to submit the data to the State Board of Education, which must submit a public report to the legislature. However, Section 28(e) and (f) proscribe public disclosure of information obtained under the section that personally identifies a student (except for purposes permitted by 8 U.S.C. §§ 1371 and 1644

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Bluebook (online)
443 F. App'x 411, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-state-of-alabama-ca11-2011.