Amicus Curiae Brief — James Uthmeier, Attorney General of Florida, et al., Applicants v. Florida Immigrant Coalition, et al.

No. 24A1269

In the Supreme Court of the United States

__________

JAMES UTHMEIER, ATTORNEY GENERAL OF FLORIDA,

ET AL.,

Applicants,

v.

FLORIDA IMMIGRANT COALITION, ET AL.,

__________

Respondents.

ON APPLICATION FOR STAY PENDING APPEAL FROM THE

U.S. COURT OF APPEALS FOR THE ELEVENTH CIRCUIT

__________

BRIEF FOR AMERICA FIRST LEGAL FOUNDATION

AS AMICUS CURIAE IN SUPPORT OF APPLICANTS

__________

DANIEL Z. EPSTEIN

America First Legal Foundation

611 Pennsylvania Avenue SE #231

Washington, DC 20003

(202) 964-3721

daniel.epstein@aflegal.org

CHRISTOPHER E. MILLS

Counsel of Record

Spero Law LLC

557 East Bay Street #22251

Charleston, SC 29413

(843) 606-0640

cmills@spero.law

Counsel for Amicus Curiae

TABLE OF CONTENTS

Table of Authorities ....................................................................................................... ii

Interest of Amicus Curiae.............................................................................................. 1

Summary of the Argument ............................................................................................ 1

Argument ....................................................................................................................... 3

I. Preemption requires a federal–state conflict; overlap is not enough. ................ 3

II. Federal law does not preempt Florida’s law. ....................................................... 6

Conclusion .................................................................................................................... 13

TABLE OF AUTHORITIES

CASES

Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1 (2013)............................. 7

Arizona v. United States, 567 U.S. 387 (2012) ..................................................... 10, 12

Bd. of Governors of Fed. Rsrv. Sys. v. Dimension Fin. Corp., 474 U.S. 361 (1986)... 10

California v. ARC Am. Corp., 490 U.S. 93 (1989) ...................................................... 12

California v. Zook, 336 U.S. 725 (1949) .................................................................... 5, 8

Chamber of Com. of U.S. v. Whiting, 563 U.S. 582 (2011) ....................................... 5, 8

Crosby v. Nat’l Foreign Trade Council, 530 U.S. 363 (2000) ....................................... 3

CSX Transp., Inc. v. Easterwood, 507 U.S. 658 (1993) ................................................ 7

DeCanas v. Bica, 424 U.S. 351 (1976) ................................................................... 10, 12

English v. Gen. Elec. Co., 496 U.S. 72 (1990) ....................................................... 3, 6, 9

Gregory v. Ashcroft, 501 U.S. 452 (1991) ...................................................................... 3

Hillsborough Cnty. v. Automated Med. Lab’ys, Inc., 471 U.S. 707 (1985) ............... 4, 6

Kansas v. Garcia, 589 U.S. 191 (2020) ......................................................... 4, 6, 10, 11

Keller v. City of Fremont, 719 F.3d 931 (CA8 2013) ..................................................... 9

Kurns v. R.R. Friction Prods. Corp., 565 U.S. 625 (2012) ............................................ 3

Loper Bright Enters. v. Raimondo, 603 U.S. 369 (2024) .............................................. 4

Medtronic, Inc. v. Lohr, 518 U.S. 470 (1996) ........................................................ 5, 7, 8

PLIVA, Inc. v. Mensing, 564 U.S. 604 (2011) ............................................................... 3

Plyler v. Doe, 457 U.S. 202 (1982) ............................................................................... 12

Puerto Rico Dep’t of Consumer Affs. v. Isla Petroleum Corp.,

485 U.S. 495 (1988) .......................................................................................... 6, 9, 10

United States v. Texas, 97 F.4th 268 (CA5 2024) ....................................................... 10

Villas at Parkside Partners v. City of Farmers Branch, 726 F.3d 524 (CA5 2013) ... 12

Virginia Uranium, Inc. v. Warren, 587 U.S. 761 (2019) .............................................. 9

Wyeth v. Levine, 555 U.S. 555 (2009) ............................................................................ 3

Zyla Life Scis., LLC v. Wells Pharma of Houston, LLC,

134 F.4th 326 (CA5 2025) ............................................................................ 5, 6, 8, 11

CONSTITUTIONAL PROVISIONS

U.S. Const. art. I, § 10 ................................................................................................... 3

U.S. Const. art. VI, cl. 2 ................................................................................................. 3

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U.S. Const. amend. X ..................................................................................................... 3

STATUTES

8 U.S.C. § 1324a ............................................................................................................. 9

8 U.S.C. § 1325 ..................................................................................................... 7, 9, 11

8 U.S.C. § 1326 ......................................................................................................... 7, 11

Fla. Stat. § 811.101 ........................................................................................................ 2

Fla. Stat. § 811.102 .................................................................................................... 2, 7

Fla. Stat. § 811.103 .................................................................................................... 2, 7

Fla. Stat. § 908.111 ........................................................................................................ 2

OTHER AUTHORITIES

Exec. Order No. 14159, 90 Fed. Reg. 8443 (Jan. 20, 2025) ...................................... 1, 2

Note, Preemption As Purposivism’s Last Refuge,

126 Harv. L. Rev. 1056 (2013) ............................................................................. 4, 10

Off. Legal Couns., Non-Preemption of the Authority of State and Local Law

Enforcement Officials to Arrest Aliens for Immigration Violations (2002),

https://perma.cc/TS4N-J4D5.................................................................................... 11

S. Gardbaum, The Nature of Preemption, 79 Corn. L. Rev. 767 (1994) ................... 4, 5

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INTEREST OF AMICUS CURIAE

America First Legal Foundation is a nonprofit organization dedicated to

promoting the rule of law in the United States by ensuring due process and equal

protection for every American citizen and encouraging understanding of the law and

individual rights guaranteed under the Constitution and laws of the United States.

AFL has a substantial interest in this case. Ensuring compliance with the Nation’s

immigration laws, protecting national sovereignty, and promoting the rule of law are

core institutional interests at the heart of its mission. *

SUMMARY OF THE ARGUMENT

Facing States in this country is “an unprecedented flood of illegal immigration.”

Exec. Order No. 14159 § 1, 90 Fed. Reg. 8443 (Jan. 20, 2025). These illegal immigrants can “present significant threats to national security and public safety,

committing vile and heinous acts against innocent Americans.” Ibid. Some are

“engaged in hostile activities, including espionage, economic espionage, and

preparations for terror-related activities.” Ibid. And “[m]any have abused the

generosity of the American people, and their presence in the United States has cost

taxpayers billions of dollars at the Federal, State, and local levels.” Ibid. Thus, the

United States recently reiterated its “obligation to prioritize the safety, security, and

financial and economic well-being of Americans,” including by working with “State

and local law enforcement agencies.” Id. §§ 1, 11.

* In accordance with Rule 37.6, no counsel for a party authored this brief in whole or in part, and no

person or entity, other than amicus curiae, its members, or its counsel, made a monetary contribution

to its preparation or submission.

The State of Florida especially suffered from the influx of illegal immigrants

“[o]ver the last 4 years.” Id. § 1. Not only did its citizens face safety and employment

challenges from illegal immigration, but its public health and welfare systems—

funded by taxpaying citizens—were drained. To address these severe burdens,

Florida recently prohibited entry into and presence within Florida by illegal

immigrants. Fla. Stat. §§ 811.102, 811.103. Florida’s definition of “unauthorized

alien” tracks the definition in “the federal Immigration and Nationality Act” and

“shall be interpreted consistently with any applicable federal statutes, rules, or

regulations.” Id. § 908.111(1)(d); see id. § 811.101(2). After making an arrest under

this law, Florida law enforcement must notify the federal Department of Homeland

Security with details about the unauthorized alien. This statute promotes the federal

interest in using “all available law enforcement tools to faithfully execute the

immigration laws of the United States.” Exec. Order. No. 14159 § 6(c).

Yet the courts below held that challengers to the law were likely to succeed in

showing that Florida law is preempted by the federal law that it mirrors. That holding

was in error. Preemption requires some conflict between federal and state law; mere

overlap is not enough. But there is no conflict here: Florida law prohibits entry into

and presence in Florida by individuals not lawfully authorized to be anywhere in the

United States. Federal law does not guarantee the ability of unauthorized aliens to

enter Florida or any other State. Thus, the lower courts erred in holding that the

challengers were likely to succeed on their preemption claim, and the Court should

grant a stay.

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ARGUMENT

I. Preemption requires a federal–state conflict; overlap is not enough.

“The Supremacy Clause establishes that federal law ‘shall be the supreme Law of

the Land . . . any Thing in the Constitution or Laws of any State to the Contrary

notwithstanding.’” PLIVA, Inc. v. Mensing, 564 U.S. 604, 617 (2011) (quoting U.S.

Const. art. VI, cl. 2). Under this Clause, “state law is naturally preempted to the

extent of any conflict with” federal law. Crosby v. Nat’l Foreign Trade Council, 530

U.S. 363, 372 (2000). But it cannot be preempted absent a conflict. The States have

general police power to legislate unless prohibited by the Constitution. See U.S.

Const. amend. X; id. art. I, § 10; Gregory v. Ashcroft, 501 U.S. 452, 457–58 (1991). So

only if federal law requires preemption of state law—either expressly or impliedly,

because the laws are in contradiction—must state law yield. See Kurns v. R.R.

Friction Prods. Corp., 565 U.S. 625, 630 (2012). Otherwise, state law cannot be

superseded. See Wyeth v. Levine, 555 U.S. 555, 565 (2009).

The courts below relied on field preemption, a type of implied preemption. Under

this doctrine, “state law is pre-empted where it regulates conduct in a field that

Congress intended the Federal Government to occupy exclusively.” English v. Gen.

Elec. Co., 496 U.S. 72, 79 (1990). Field preemption is properly “understood as a species

of conflict pre-emption: A state law that falls within a pre-empted field conflicts with

Congress’ intent (either express or plainly implied) to exclude state regulation.” Id.

at 79 n.5. Of course, if Congress’s intent is express, then express preemption can be

found. So field preemption becomes relevant only when Congress declined to

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expressly preempt state law, it is possible to comply with both sets of laws, and there

is no direct conflict otherwise between the laws.

Field preemption is—and should be—“rare.” Kansas v. Garcia, 589 U.S. 191, 208

(2020); see id. at 214 n.* (Thomas, J., concurring). Indeed, the doctrine sits uneasily

with modern principles of statutory interpretation and federalism. “[A]t the outset of

th[e] [field preemption] analysis courts must confront a puzzler: how could Congress

have ‘left no room for supplementary state regulation’ when the [federal] statute

le[aves] open the precise type of state regulation at issue?” Note, Preemption As

Purposivism’s Last Refuge, 126 Harv. L. Rev. 1056, 1068 (2013). “[M]erely because

the federal provisions [a]re sufficiently comprehensive to meet the need identified by

Congress d[oes] not mean that States and localities [a]re barred from identifying

additional needs or imposing further requirements in the field.” Hillsborough Cnty.

v. Automated Med. Lab’ys, Inc., 471 U.S. 707, 717 (1985).

“Presumptions have their place in statutory interpretation, but only to the extent

that they approximate reality.” Loper Bright Enters. v. Raimondo, 603 U.S. 369, 399

(2024). And “the doctrine that comprehensive regulation automatically provides

evidence of congressional intent to preempt ignores alternative interpretations of that

intent in a way that potentially distorts the result that would be reached upon a fair

reading of the statute.” S. Gardbaum, The Nature of Preemption, 79 Corn. L. Rev.

767, 812 (1994). After all, “Congress may perfectly plausibly intend or not intend to

preempt the states regardless of the pervasiveness of its scheme of regulation.” Ibid.

For instance, “Congress may intend that states be allowed to supplement federal

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regulation,” it “may not have considered whether or not to preempt,” or it “may have

considered preemption without reaching any conclusion.” Ibid. “[O]rdinary statutory

interpretation” thus “provides little support for any analysis suggesting that

extensive occupation of a field automatically creates a presumption of intent to

preempt.” Ibid. If anything, field preemption seems to be “artificially imposed on the

interpretive process as a holdover from the period before the radical expansion in the

scope of Congress’s interstate commerce power.” Ibid. By making unfounded

assumptions about congressional intent, field preemption may “undercut the

principle that it is Congress rather than the courts that pre-empts state law.”

Chamber of Com. of U.S. v. Whiting, 563 U.S. 582, 607 (2011) (plurality opinion).

Field preemption is also often “inconsistent with modern federalism and its

presumption that states retain concurrent powers.” Gardbaum, supra, at 812.

“[B]ecause the States are independent sovereigns in our federal system, [courts] have

long presumed that Congress does not cavalierly pre-empt state-law causes of action.”

Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996). “States may have a legitimate

interest in punishing or providing redress for wrongs even if federal law already does

so.” Zyla Life Scis., LLC v. Wells Pharma of Houston, LLC, 134 F.4th 326, 333 (CA5

2025). For instance, “[t]he Federal Government is not the only one with an interest

in criminalizing murder or rape.” Ibid.; see California v. Zook, 336 U.S. 725, 738

(1949) (“[T]he State may punish . . . for the safety and welfare of its inhabitants; the

nation may punish for the safety and welfare of interstate commerce. There is no

conflict.”). And “the Federal Government often has an interest in allowing parallel

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state regulation.” Zyla, 134 F.4th at 333. It has “limited resources” so “often welcomes

state aid in enforcing shared legal norms.” Id. at 334.

For all these reasons, courts must carefully “look for special features warranting

pre-emption” based on supposed federal occupation of a regulatory field.

Hillsborough, 471 U.S. at 719. “[O]therwise, deliberate federal inaction could always

imply pre-emption, which cannot be.” Puerto Rico Dep’t of Consumer Affs. v. Isla

Petroleum Corp., 485 U.S. 495, 503 (1988). Mere “overlap” is not enough. Garcia, 589

U.S. at 211. As shown next, the courts below failed here to identify any special

features warranting preemption of Florida’s regulation of entry into and presence

within the State.

II. Federal law does not preempt Florida’s law.

As this Court has explained, “[t]he question whether the regulation of an entire

field has been reserved by the Federal Government is, essentially, a question of

ascertaining the intent underlying the federal scheme.” Hillsborough, 471 U.S. at

714. Generally, “[s]uch an intent may be inferred from a scheme of federal regulation

so pervasive as to make reasonable the inference that Congress left no room for the

States to supplement it, or where an Act of Congress touches a field in which the

federal interest is so dominant that the federal system will be assumed to preclude

enforcement of state laws on the same subject.” English, 496 U.S. at 79 (cleaned up).

Critically, however, “‘[t]here is no federal preemption in vacuo,’ without a

constitutional text, federal statute, or treaty made under the authority of the United

States.” Garcia, 589 U.S. at 202 (quoting Puerto Rico, 485 U.S. at 503). While the

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Court has “frequently said that pre-emption analysis requires ascertaining

congressional intent,” it has “never meant that to signify congressional intent in a

vacuum, unrelated to the giving of meaning to an enacted statutory text.” Puerto Rico,

485 U.S. at 501. Rather, “[e]vidence of pre-emptive purpose is sought in the text and

structure of the statute at issue.” CSX Transp., Inc. v. Easterwood, 507 U.S. 658, 664

(1993); see Garcia, 589 U.S. at 202 (“‘Invoking some brooding federal interest or

appealing to a judicial policy preference’ does not show preemption.”); see also

Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1, 14 (2013) (“[T]he statutory

text accurately communicates the scope of Congress’s pre-emptive intent.”).

Preemption analysis begins with “a careful comparison between the allegedly preempting federal requirement and the allegedly pre-empted state requirement.”

Medtronic, 518 U.S. at 500. Here, federal law prohibits entry into and presence in the

United States by certain unauthorized aliens. 8 U.S.C. §§ 1325, 1326. Florida law, in

turn, prohibits entry into and presence in Florida by the same set of unauthorized

aliens. Fla. Stat. §§ 811.102, 811.103. It also requires that “the arresting law

enforcement agency” notify the federal government of the alien’s arrest. Id.

§§ 811.102(7), 811.103(6).

There is no conflict between these provisions. Specifically, there is no conflict

between the United States excluding unauthorized aliens and Florida excluding the

same unauthorized aliens. The courts below did not explain a plausible reading of the

federal statutes that would suggest Congress disapproved of state efforts to limit

entry by persons whose entry it was also prohibiting. Florida is not regulating the

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entry or reentry of anyone into the United States. It is only regulating the entry or

reentry of a group of people with respect to Florida—and echoing the federal

regulation. By “us[ing] the Federal Government’s own definition of ‘unauthorized

alien,’” Florida “has taken the route least likely to cause tension with federal law.”

Whiting, 563 U.S. at 611 (emphasis added); cf. Medtronic, 518 U.S. at 495 (no

preemption where state “duties parallel federal requirements”); Zook, 336 U.S. at 735

(explaining that “there is no conflict in terms, and no possibility of such conflict,

[when] the state statute makes federal law its own”); Zyla, 134 F.4th at 334–35

(collecting “many state statutes [that] incorporate federal criminal requirements”).

Indeed, there would not be a conflict even if Florida law swept beyond the federal

law about alien entry, for nothing in the federal statutes cited by the challengers

gives unauthorized aliens or anyone else the right to enter Florida. By analogy,

suppose that Florida banned the entry or presence of persons convicted of any federal

crime. The statutory preemption question would be whether any federal statute

required Florida to allow convicted criminals to enter or remain in the state. Absent

such a statute, that Congress had criminalized the underlying conduct—or imposed

its own limitations on criminals’ interstate movements—does not suggest an intent

to guarantee individuals the right to enter particular states.

So too here. The federal statutes set a regulatory floor for entry and reentry into

the United States. Nothing in the text of the relevant provisions suggests that

Congress wanted that floor to be a ceiling for individual States, too. Congress knows

how to preempt state laws pertaining to immigration when it wants to. See, e.g., 8

8

U.S.C. § 1324a(h)(2) (preempting certain state laws “imposing civil or criminal

sanctions” “upon those who employ, or recruit or refer for a fee for employment,

unauthorized aliens”). But it did not do so here. And “[l]aws designed to deter, or even

prohibit, unlawfully present aliens from residing within a particular locality are not

tantamount to immigration laws establishing who may enter or remain in the

country.” Keller v. City of Fremont, 719 F.3d 931, 941 (CA8 2013).

Courts may not “seek[] out conflicts between state and federal regulation where

none clearly exists.” English, 496 U.S. at 90. Yet the courts below “draw exaggerated

inferences from” generic descriptions of federal immigration law as “comprehensive.”

Puerto Rico, 485 U.S. at 503; see App. 8a, 264a. One might wonder whether the short

statutes in §§ 1325 and 1326 can fairly be characterized as “comprehensive,” at least

in a way that would not apply to the whole federal code. At any rate, “[a] sound

preemption analysis cannot be as simplistic as that.” Virginia Uranium, Inc. v.

Warren, 587 U.S. 761, 778 (2019) (opinion of Gorsuch, J.). Supposed “comprehensiveness” only matters to preemption if “a comprehensive federal scheme intentionally

leaves a portion of the regulated field without controls.” Puerto Rico, 485 U.S. at 503.

Only in that circumstance—when there is federal “inaction joined with action”—can

a “pre-emptive inference can be drawn.” Ibid.

But there is nothing like that here, for there is no relevant “inaction” prescribed

by these federal statutes. They prohibit the same thing as Florida law does: entry and

presence by unauthorized aliens. The federal statutes do not suggest any intent to

prohibit overlapping state regulation. And “[w]ithout a text that can . . . plausibly be

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interpreted as prescribing federal pre-emption[,] it is impossible to find that” entry

into Florida without state consequence is “mandated by federal law.” Puerto Rico, 485

U.S. at 501. Invocation of broad-brush descriptions “of legislation at the expense of

the terms of the statute itself . . . prevents the effectuation of congressional intent.”

Bd. of Governors of Fed. Rsrv. Sys. v. Dimension Fin. Corp., 474 U.S. 361, 374 (1986).

The courts below also extrapolated from field preemption of alien registration

statutes in Arizona v. United States, 567 U.S. 387, 401 (2012) (“field of alien

registration”), to field preemption of “control[ling] immigration” broadly. App. 267a;

see App. 8a–9a. But this Court “has never extended field preemption to any part of

the immigration laws beyond alien registration.” United States v. Texas, 97 F.4th 268,

298 (CA5 2024) (Oldham, J., dissenting). That federal law might “create a

comprehensive and unified system” for alien registration does not mean that federal

law comprehensively regulates immigration generally or entry into each State

specifically. Garcia, 589 U.S. at 210.

What’s more, this invocation of a broader field underscores the danger that field

preemption may “give[] the courts power to affect the federal-state balance by

choosing the level of generality at which to define the relevant field.” Note, supra, at

1067. Because of that danger, this Court has repeatedly warned that courts must

carefully identify “the boundaries of th[e] field before [saying] that it has precluded a

state from the exercise of any power reserved to it by the Constitution.” DeCanas v.

Bica, 424 U.S. 351, 360 n.8 (1976); see Garcia, 589 U.S. at 208 (rejecting an effort to

10

“define the supposedly preempted field more broadly”). Nothing in §§ 1325 or 1326

reflects a preemptive intent with respect to alien entry or presence.

The district court discerned purported conflicts between Florida and federal law

because an alien might be penalized under state law but escape or suffer less penalty

under federal law, for instance, when “federal actors may choose not to” prosecute

illegal immigrants. App. 266a. But that is true of every regime with overlapping

federal and state regulation. A murderer might face heightened state law

consequences—for instance, in periods when the federal government refuses to seek

the death penalty—but no one could suggest that the federal prohibitions on murder

conflict with state prohibitions. “[I]n the vast majority of cases where federal and

state laws overlap, allowing the States to prosecute is entirely consistent with federal

interests.” Garcia, 589 U.S. at 212. So it is here, given that Florida’s prosecution of

its law mimics and is directly tied to enforcement of federal law. Cf. Off. Legal Couns.,

Non-Preemption of the Authority of State and Local Law Enforcement Officials to

Arrest Aliens for Immigration Violations (2002), https://perma.cc/TS4N-J4D5

(explaining that States may make arrests for federal immigration law violations).

The implications of the district court’s contrary theory “are staggering,”

particularly “[g]iven the extraordinary reach of federal law” in the modern era. Zyla,

134 F.4th at 335. “Practically any conduct the State wants to regulate is already

regulated by the Federal Government.” Ibid. So if the federal system is to be

preserved, States cannot be prevented “from regulating [any]thing federal law

touches.” Ibid. As this Court said in Garcia, “[o]ur federal system would be turned

11

upside down if [courts] were to hold that federal . . . law preempts state law whenever

they overlap.” 589 U.S. at 212; see California v. ARC Am. Corp., 490 U.S. 93, 105

(1989) (“[S]tate causes of action are not pre-empted solely because they impose

liability over and above that authorized by federal law.”); see also Villas at Parkside

Partners v. City of Farmers Branch, 726 F.3d 524, 577–78 (CA5 2013) (Jones, J.,

dissenting) (“[C]ourts do not normally call this phenomenon ‘conflict preemption.’

Instead, we call it ‘federalism.’”).

Last, the Eleventh Circuit emphasized “the federal government’s longstanding

and distinct interest in the exclusion and admission of aliens.” App. 9a. But as this

Court has recognized, States have their own interest in “immigration policy,” for they

“bear[ ] many of the consequences of unlawful immigration.” Arizona, 567 U.S. at 397.

“The problems posed to the State by illegal immigration must not be underestimated.”

Id. at 398; see Plyler v. Doe, 457 U.S. 202, 228 n.23 (1982) (recognizing that

“unchecked unlawful migration might impair the State’s economy generally, or the

State’s ability to provide some important service[s]”). So it is unremarkable that

Florida would choose to implement its own regulations to address the many burdens

of illegal immigration into the State. And there is no predominant “federal interest

in a situation in which the state law is fashioned to remedy local problems,” especially

when it operates “only with respect to individuals whom the Federal Government has

already declared cannot” be in the United States. DeCanas, 424 U.S. at 363. The

challengers here failed to show “evidence that Congress has unmistakably ordained

exclusivity of federal regulation in this field.” Id. at 361 (cleaned up).

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CONCLUSION

For these reasons, the Court should grant a stay.

Respectfully submitted,

DANIEL Z. EPSTEIN

America First Legal Foundation

611 Pennsylvania Avenue SE #231

Washington, DC 20003

(202) 964-3721

daniel.epstein@aflegal.org

CHRISTOPHER E. MILLS

Counsel of Record

Spero Law LLC

557 East Bay Street #22251

Charleston, SC 29413

(843) 606-0640

cmills@spero.law

Counsel for Amicus Curiae

JULY 2, 2025

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