Amicus Curiae Brief — Donald J. Trump, President of the United States, et al., Applicants v. Illinois, et al.
Supreme Court briefOct 24, 2025
Ask Donna
What actually matters in this document.
Text
No. 25A443
IN THE
SUPREME COURT OF THE UNITED STATES
_____________________________________________________________________________
DONALD J. TRUMP, in his official capacity as President of the United States, et al.
Applicants,
v.
STATE OF ILLINOIS, et al.,
Respondents.
____________________________________________________________________________
ON APPLICATION TO STAY THE TEMPORARY RESTRAINING ORDER ISSUED BY THE
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS
BRIEF OF AMICI CURIAE LOCAL GOVERNMENTS AND
LOCAL GOVERNMENT LEADERS IN SUPPORT OF RESPONDENTS’
RESPONSE IN OPPOSITION TO THE EMERGENCY MOTION
FOR STAY PENDING APPEAL
JENNY S. MA
Counsel of Record
JONATHAN B. MILLER
JEAN LARSEN
PUBLIC RIGHTS PROJECT
490 43rd Street, Unit #115
Oakland, CA 94609
(510) 738-6788
jenny@publicrightsproject.org
Counsel for Amici Curiae
TABLE OF CONTENTS
TABLE OF AUTHORITIES ..................................................................... ii
INTEREST OF AMICI CURIAE .............................................................. 1
SUMMARY OF ARGUMENT .................................................................. 4
ARGUMENT ............................................................................................. 6
I. IF THE STATUS QUO IS NOT MAINTAINED, THE
GOVERNMENT WILL UNLEASH MILITARY FORCES
WITHOUT FACTUAL JUSTIFICATION AND UNDER
PRETEXT THAT WILL SEVERELY HARM AMICI AND THE
PUBLIC INTEREST ........................................................................... 6
A. The Unlawful Federalization of the National Guard
Without Justification Harms State and Local Sovereignty ......... 8
B. The Public Interest Is Best Served When Local Law
Enforcement, Not Federalized Military Forces, Exercise
Police Powers to Ensure Public Safety and Manage Local
Protests ......................................................................................... 11
1. Local law enforcement has specific expertise to respond
to protests and to de-escalate ................................................. 12
2. The deployment of the National Guard has escalated
conflict and made it harder for local law enforcement to
do its job .................................................................................. 15
C. Actual and Threatened Militarization of Our Cities
Disturbs Our Residents’ Well-Being and Our Local
Economies ..................................................................................... 18
CONCLUSION ........................................................................................ 22
ADDITIONAL COUNSEL ...................................................................... 24
Appendix A – List of Amici Curiae ........................................................ 28
i
TABLE OF AUTHORITIES
CASES
Barnes v. E-Sys., Inc. Grp. Hosp. Med. & Surgical Ins. Plan,
501 U.S. 1301 (1991) ............................................................................. 7
Coyle v. Smith,
221 U.S. 559 (1911) ............................................................................... 9
Grider v. Abramson,
180 F.3d 739 (6th Cir. 1999) ............................................................... 12
Illinois v. Trump,
No. 1:25-cv-12174 (N.D. Ill. Oct. 6, 2025) ...... 2, 6, 8–10, 13–17, 19, 22
Illinois v. Trump,
No. 25-2798 (7th Cir. Oct. 16, 2025) ................................................ 7, 9
Laird v. Tatum,
408 U.S. 1 (1972) ................................................................................... 8
Newsom v. Trump,
141 F.4th 1032 (9th Cir. 2025) ........................................................... 16
Newsom v. Trump,
786 F. Supp. 3d 1235 (N.D. Cal. 2025)............................................... 10
Nken v. Holder,
556 U.S. 418 (2009) ............................................................................... 7
Ohio v. Env’t Prot. Agency,
603 U.S. 279 (2024) ............................................................................... 7
Oregon v. Trump,
No. 25-cv-01756 (D. Or. Oct. 4, 2025) ................................................ 16
Printz v. United States,
521 U.S. 898 (1997) ............................................................................... 8
San Francisco v. Trump,
783 F. Supp. 3d 1148 (N.D. Cal. 2025)............................................... 11
San Francisco v. Trump,
897 F.3d 1225 (9th Cir. 2018) ............................................................. 11
ii
Swain v. Junior,
958 F.3d 1081 (11th Cir. 2020) ........................................................... 17
Trump v. Int’l Refugee Assistance Project,
582 U.S. 571 (2017) ............................................................................... 7
Walker v. Birmingham,
388 U.S. 307 (1967) ............................................................................. 11
STATUTES
10 U.S.C. § 12406 .................................................................................... 10
CONSTITUTIONAL PROVISIONS
Cal. Const., art. XI, § 5 ............................................................................. 8
Cal. Const., art. XI, § 7 ............................................................................. 8
Ill. Const., art. VII, § 6 .............................................................................. 8
N.M. Const., art. 10, § 6 ............................................................................ 8
OTHER AUTHORITIES
Alana Wise, The National Guard has Been Deployed to Enforce
the Law Before. What’s Different Now?, Nat’l Public Radio,
(Aug. 21, 2025) .............................................................................. 13, 17
Alex Horton, National Guard Documents Show Public ‘Fear,’
Veterans ‘Shame’ Over D.C. Presence, Wash. Post (Sept. 10,
2025) .............................................................................................. 18, 21
Andrea Sachs & Federica Cocco, D.C. Tourism Was Already
Struggling, Then the National Guard Arrived, Wash. Post
(Aug. 29, 2025) .................................................................................... 19
Andrew Schwartz, National Guard Deployment—Estimated Cost:
$10 Million—Crawls Along, Willamette Week (Oct. 1, 2025) .......... 22
Anna Griffin, In 2020, Trump Intervened in Portland’s Protests.
They Got Even Worse, N.Y. Times (Oct. 7, 2025) .............................. 16
Antje Blinde et al., International Travelers Are Growing Skeptical
of the U.S., Spiegel Int’l, (June 19, 2025) .......................................... 21
iii
Billal Rahman, ICE Accidentally Tear Gases Chicago Police
During Clash With Protesters, Newsweek (Oct. 6, 2025) .................. 16
C. Todd Lopez, National Guard Provides Support to Hurricane
Stricken States, Department of War (Oct. 3, 2024) ........................... 11
Demonstrations and Political Violence in America: New Data for
Summer 2020, ACLED (Sept. 3, 2020) .............................................. 11
Ed White & Christopher L. Keller, Trump’s Push for More Troops
in US Cities at Odds with Crime Stats, Military Times (Aug.
29, 2025) .............................................................................................. 18
Immigration Raids and Military Presence Hurting Economy in
Santa Ana, Employees Say, ABC 7 News (Jun. 11, 2025) ................ 20
Josh Marcus, Trump mobilizing up to 1,700 National Guard
troops in 19 states to widen crime and immigration crackdown,
The Independent (Aug. 25, 2025) ......................................................... 2
Joshua Chapin, Downtown DC Businesses Hope for Increased
Foot Traffic After End To Federal Takeover, ABC 7 News (Sept.
11, 2025) .............................................................................................. 18
Marc Novicoff, A Very, Very Expensive Way to Reduce Crime, The
Atlantic (Oct. 10, 2025) ....................................................................... 22
Megan Lebowitz, Trump Says Gov. JB Pritzker and Chicago
Mayor Brandon Johnson 'Should be in Jail', NBC News (Oct.
8, 2025) ................................................................................................ 19
Melody Gutierrez, Trump’s Military Deployment in L.A. Cost $120
Million, Newsom Says, LA Times (Sept. 4, 2025) ............................. 22
Memorandum on Restoring Law and Order in Memphis (Sept. 15,
2025) .................................................................................................... 20
Memorandum on Restoring Law and Order in the District of
Columbia, (Aug. 11, 2025) .................................................................. 20
Meredith Lee Hill & Jennifer Scholtes, Trump’s troop pay move is
a ‘temporary fix,’ Johnson says, Politico (Oct. 15, 2025) ................... 22
Milton Guevara, How National Guard Troops in D.C. Are
Affecting Restaurants in the Capital, Nat’l Public Radio (Sept.
1, 2025) ................................................................................................ 19
iv
Mimi Montgomery, Trump Crackdown is Affecting D.C.’s Image
and Tourism Numbers, Axios D.C. (Aug. 29, 2025) .......................... 19
Noah Robertson, LA Deployments to Cost $134 Million and Last
60 Days, Pentagon Says, Military Times (June 10, 2025) ................ 22
Pittsburgh Bureau of Police Roadway Safety Guidelines (July 26,
2018) .................................................................................................... 14
President Donald Trump, Address to Military Leadership in
Quantico, Virginia (Sept. 30, 2025) ............................................ 1, 2, 17
President Donald Trump, Comments to Reporters Before Air
Force One Departure (June 8, 2025)................................................... 2
President Donald Trump, Remarks During Bilat with Javier
Melei of Argentina in Washington, D.C. (Oct. 14, 2025) .................. 21
President Donald Trump, Speech Announcing Military
Deployment in Washington, D.C. (Aug. 11, 2025) .............................. 2
President Donald Trump, Speech on Signing Executive Order on
Alaskan Energy and Minerals in Washington, D.C. (Oct. 6,
2025) .................................................................................................... 17
Press Release, City of New Haven, Statement by Mayor Elicker on
Yale University Students Protest and Successful De-escalation
by the New Haven Police Department (Apr. 23, 2024) ...................... 14
Schwalb Decl., D.C. v. Trump, No. 25-cv-3005 (D.D.C. 2025), Dkt.
No. 3-5.................................................................................................. 19
The Federalist No. 39 ............................................................................... 8
The White House, Additional Measures to Address the Crime
Emergency in the District of Columbia, § 2(d)(ii) (Aug. 25, 2025)
............................................................................................................... 2
Trump Hints He Could Send National Guard to Oakland, Fox
KTVU (Aug. 12, 2025)......................................................................... 20
Will Weissert & Sophia Tareen, Trump says he’s set to order
federal intervention in Chicago and Baltimore, despite local
opposition, Associated Press (Sept. 2, 2025) ........................................ 2
v
INTEREST OF AMICI CURIAE
Amici curiae are local governments and officials from across the Nation.1 Their
municipalities and counties differ in size, demographics, and policy priorities, but
share a common interest in keeping communities safe, protecting the First
Amendment rights of their residents, and avoiding pretextual punishment by the
Executive branch. Through decades of experience, amici have successfully deployed
policies and practices that balance public safety needs with the rights of their
residents.
The President has made plain his desire to treat American cities as military
“training grounds.”2 Since federalizing and deploying the National Guard in Los
Angeles in June, the Administration has sent or attempted to send federal military
troops into one community after the next—each time, widening the scope, duration,
and reason for deployment. In just the past three weeks, the President has federalized
and attempted to deploy hundreds more troops, including out-of-state troops, into the
City of Portland twice, while simultaneously attempting to do the same in and around
Respondent City of Chicago. The President has also made new and repeated avowals
to expand National Guard deployments to other cities, “where needed,” including
1 Pursuant to Supreme Court Rule 37.6, no party or party’s counsel authored this
brief in whole or in part and no party or party’s counsel contributed money intended
to fund preparation or submission of this brief. A list of all amici is provided at
Appendix A.
2 President Donald Trump, Address to Military Leadership in Quantico, Virginia
(Sept. 30, 2025) (transcript available via Roll Call, https://perma.cc/HHS8-HR8S).
1
some amici.3 On top of this, in as many as nineteen states, the Administration plans
to deploy the National Guard under state control to assist with federal immigration
enforcement.4 In anticipation of this planned roll-out, the President has issued an
Executive Order instructing the Secretary of Defense to establish a “standing
National Guard quick reaction force” available for “rapid nationwide deployment.”5
Taken together, these deployments of the National Guard across the country
constitute a perilous increase in the presence and threatened presence of military
troops in cities and localities like those amici represent. President Trump’s promise
that “we’re gonna have troops everywhere”6 raises serious concerns of the cascading
3 See Memorandum for the Adjutant General, Texas National Guard, Dkt. No.
13-4,
Illinois v. Trump, No. 1:25-cv-12174 (N.D. Ill. filed Oct. 6, 2025) (authorizing
mobilization of up to 400 Texas National Guard members “where needed, including
in the cities of Portland and Chicago”); see also Will Weissert & Sophia Tareen,
Trump says he’s set to order federal intervention in Chicago and Baltimore, despite
local opposition, Associated Press (Sept. 2, 2025), https://perma.cc/T4QB-7CZT
(including Baltimore on the list of cities where Trump is considering sending federal
authorities); President Donald Trump, supra n.2 (including New York and San
Francisco in list of “very unsafe places” that the administration is going to “straighten
[] out”); President Donald Trump, Speech Announcing Military Deployment in
Washington, D.C. (Aug. 11, 2025) (transcript available via Roll Call,
https://perma.cc/SPQ6-8NWH) (describing Baltimore, Oakland and New York as
cities that are “bad, very bad”).
4 Josh Marcus, Trump mobilizing up to 1,700 National Guard troops in 19 states to
widen crime and immigration crackdown, The Independent (Aug. 25, 2025),
https://perma.cc/6U2S-KEP8.
5 The White House, Additional Measures to Address the Crime Emergency in the
District of Columbia, § 2(d)(ii) (Aug. 25, 2025), https://perma.cc/3AF2-QMQ4.
6 President Donald Trump, Comments to Reporters Before Air Force One Departure
(June 8, 2025) (transcript available via Roll Call, https://perma.cc/3UX6-DAQY).
2
harms to amici’s jurisdictions if the Court grants the Government’s application and
allows the deployment to proceed unfettered.
As in other jurisdictions, by federalizing the National Guard in Chicago, the
Government failed to meet statutory thresholds and threatens to trample the
foundational principles forbidding federal military involvement in civilian law
enforcement. Amici are gravely concerned that any protest within their borders, or
any claim by the Government of an unfilled “security void” by local authorities, will
trigger yet another unnecessary deployment of the military. The Government’s
standardless federalization of the National Guard not only harms amici’s sovereign
interests in exercising police powers, but it also disturbs amici’s interest in peace and
tranquility, and in the well-being of our residents and our local economies. More
broadly, amici have an interest in maintaining the distinct characteristics that make
each of their communities unique and in avoiding the damage the federal usurpation
of police powers may inflict.
Amici counties and cities and their elected leaders include municipalities that
have been specifically targeted, and others that have been threatened with National
Guard deployment by Applicants. Whether facing current, recently threatened, or
potential future National Guard deployment, they have been harmed and continue to
be so. They all share a strong interest in ensuring that unnecessary deployments
cease and that adherence to the rule of law is restored. Amici respectfully submit this
brief in support of Respondents’ response in opposition to the Government’s
emergency motion for stay pending appeal.
3
SUMMARY OF ARGUMENT
Our Nation’s constitutional order demands that domestic deployment of the
federal military be restricted to exceptional circumstances and that federal courts
hold the line against Executive overreach. Throughout our history, and pursuant to
the governing statutory and constitutional law, federalization and deployment of the
states’ National Guard has been a last resort, not a primary tactic, reserved for those
exceedingly rare instances of foreign invasion, violent rebellion, or where the
President is unable to execute the laws. None of these conditions are present in the
United States currently or—as relevant for this application—in the record of this
case.
Yet, domestic National Guard deployments (or at least the threat and attempt
thereof) have become almost commonplace. Chicago, the third-largest city in the
United States, is now the fifth major American city in which the President has sought
to deploy the National Guard in as many months. These attempted deployments, in
response to local demonstrations—nothing amounting to a rebellion—intrude on
state and local sovereignty by usurping local police power; and each transgresses
further into normalizing the deployment of the military for domestic law enforcement
efforts. The threat to dual sovereignty is especially grave given the Government’s
argument that the President’s decision to deploy the National Guard domestically is
beyond review. If this Court credits that position, the Executive branch will have an
unfettered ability to seize control of a state’s National Guard for any real or imagined
reason. This cannot stand in principle or law.
4
Moreover, the public interest strongly counsels against an emergency stay.
Amici have long ably responded to demonstrations within their jurisdictions, both
when they are peaceful and otherwise, without the intrusion of the military. Contrary
to the short shrift that Applicants afford to state and local officials and law
enforcement, see Gov. Br. at 10–11, they are effective and their leadership in response
to protests or mass gatherings is the norm in American cities. Local law enforcement
is trained to respond to demonstrations large and small, whereas the National
Guard’s focus and training is on military combat and disaster response.
If left unchecked, the President’s extra-statutory National Guard deployments
will cause ongoing harm to the stability of cities across the country. Under the
Government’s reasoning, the President could issue an order seeking to federalize
troops at any time, anywhere, for any reason—based on nothing more than being a
disfavored jurisdiction, a perception that local law enforcement cannot adequately do
their jobs in their jurisdictions, or even a perceived threat of future violence.
Unwarranted military policing threatens irreparable injury not just to
Respondents, but to jurisdictions around the country. The presence of military troops
patrolling our communities inflames tensions (which, in turn, requires more
resources), endangers and decreases the efficacy of local law enforcement, and
increases risks of tragic accidents. And it disturbs our residents’ peace and well-being
and disrupts our local businesses and economies—all while costing millions of dollars.
This is especially true where, as here, military troops are deployed on city streets
5
with a muddled directive to both clean up general crime, Gaber Decl., D. Ct. Dkt. No.
13-10, ¶ 44, and to “go hard” against protesters,7 neither of which is lawful.
The Administration’s unlawful military mobilization is decisively against the
public interest. For these reasons, amici respectfully urge the Court to deny the
request for an immediate administrative stay and the stay of the district court’s
temporary restraining order.
ARGUMENT
I.
IF THE STATUS QUO IS NOT MAINTAINED, THE GOVERNMENT
WILL UNLEASH MILITARY FORCES WITHOUT FACTUAL
JUSTIFICATION AND UNDER PRETEXT THAT WILL SEVERELY
HARM AMICI AND THE PUBLIC INTEREST.
The Seventh Circuit correctly affirmed the district court’s conclusion that a
temporary restraining order is warranted to prevent an abridgement of state
sovereignty and a dramatic expansion of the President’s power. The panel—
composed of judges appointed by three presidents over the course of 25 years—
properly credited the district court’s factual findings. Given the early stage of these
proceedings, both courts appropriately recognized the determination made in holding
that none of the predicate conditions exist in Chicago for the President to federalize
and deploy the National Guard under Section 12406 was necessarily preliminary.
Having submitted no credible evidence to the district court that the facts on
the ground in Chicago require the immediate deployment of military troops because
7 Complaint, D. Ct. Dkt. No. 1 ¶¶ 113–14 (“Defendant Noem was videotaped speaking
to assembled DHS agents about protestors outside of the ICE facility in which she
stated: ‘Today, when we leave here we’re going to go hard. We’re going to hammer
these guys….’”).
6
of an inability to execute federal immigration law in that city, the Government should
not now be awarded emergency relief that dramatically alters the status quo. The
Government not only is attempting to relitigate the facts on an emergency
application, but also is attempting to relitigate facts before this Court on an
emergency application that were unpersuasive to the district and appellate courts.
Even with “great deference” afforded to the Administration's determinations, the
Seventh Circuit correctly rejected arguments that the President’s federalization of
the Guard under Section 12406 is not judicially reviewable and that there were
credible factual predicates to satisfy federalization. See Illinois v. Trump, No. 252798, at 10–16 (7th Cir. Oct. 16, 2025), Dkt. No. 26 (“App. Op.”). The court of appeals
also found that the district court “provided substantial and specific reasons” for its
credibility decisions, for which the record “includes ample support.” Id. at 12. The
Government, accordingly, has not shown a likelihood of success on the merits, and
this Court’s inquiry can end there.
Even if the other conditions for a stay could be met, this Court should
determine that “the public interest lies” in ruling against a stay application. Ohio v.
Env’t Prot. Agency, 603 U.S. 279, 291 (2024) (citing Nken v. Holder, 556 U.S. 418, 434
(2009)); see also Trump v. Int’l Refugee Assistance Project (“IRAP”), 582 U.S. 571, 580
(2017) (“Before issuing a stay, ‘[i]t is ultimately necessary . . . to balance the equities—
to explore the relative harms to applicant and respondent, as well as the interests of
the public at large.’”) (quoting Barnes v. E-Sys., Inc. Grp. Hosp. Med. & Surgical Ins.
Plan, 501 U.S. 1301, 1305 (1991)). The sovereign interests of amici weigh strongly
7
against federal military incursions into local law enforcement. Additionally, amici
urge this Court to consider the distinct and irreparable injury that local governments
nationwide suffer when the President deploys military forces to our communities.
Given the broad and substantial disruptive effect of deployment, and threatened
deployment, of the National Guard, the interests of the public at large—reflected in
amici’s coalition of local governments and leaders—strongly counsels against an
emergency stay.
A.
The Unlawful Federalization of the National Guard Without
Justification Harms State and Local Sovereignty.
A bedrock embodiment of state and local sovereignty over the police power is
the steadfast refusal to allow the military to engage in domestic policing. See Laird
v. Tatum, 408 U.S. 1, 15–16 (1972). The federalization of the National Guard in the
factual context found by the district court shatters that legal tradition. In so doing,
the Government harms Respondents’ sovereignty and similarly threatens that harm
to other localities nationwide, including amici. See D. Ct. Dkt. No. 70 (“D. Ct. Op.”),
at 49. The States’ police power manifests in significant part through county and
municipal governments, which are the primary providers of quotidian law
enforcement and public safety. See e.g., Cal. Const., art. XI, §§ 5, 7; Ill. Const., art.
VII, § 6; N.M. Const., art. 10, § 6. “As Madison expressed it: ‘[T]he local or municipal
authorities form distinct and independent portions of the supremacy, no more subject,
within their respective spheres, to the general authority than the general authority
is subject to them, within its own sphere.’” Printz v. United States, 521 U.S. 898, 920–
91 (1997) (quoting The Federalist No. 39, at 245). Local governments thus share the
8
core constitutional interest in the police power with the States under the Tenth
Amendment. Accordingly, the sovereign interests of amici cities weigh strongly
against federal military incursion into domestic local policing.
By deploying members of the Texas National Guard to Illinois, the Government
not only continues its relentless effort to dismantle the balance of power allocated by
the U.S. Constitution between the States and the federal government, but also among
the States themselves. D. Ct. Op. at 49. Indeed, as the district court explained, the
principle of equal sovereignty is violated when the National Guard from Texas is
“deployed to Illinois against the wishes of Illinois’s elected leaders” because such a
move “empowers Texas at the expense of Illinois, injuring Illinois’s right to be ‘equal
in power, dignity, and authority’ to every other state.” Id. (quoting Coyle v. Smith,
221 U.S. 559, 567 (1911)).
The threat to state and local sovereignty is underscored by the
Administration’s sweeping arguments against any judicial review. In justifying the
invasion of one state’s National Guard into another state, the Government argued
during the temporary restraining order hearing that “the federalization of the
National Guard requires no explanation, identifiable scope, or provable factual
underpinning, and that federalization determinations are immune from Article III
review.” See Appellees’ Response in Opp., 7th Cir. Dkt. No. 7 at 2 (citing to transcript).
In their view, the President may call the National Guard whenever he is “unable to
ensure to his satisfaction the faithful execution of the federal laws by the federal
officers who regularly enforce them, without undue harm or risk to officers.” D. Ct.
9
Op. at 42 (emphasis added). The Government renews this broad argument before this
Court, arguing a federal court “lacks not only the authority but also the competence”
to determine if deployment under Section 12406 is proper. Gov. Br. at 23. The
argument that this Court may not “second-guess [the President’s] judgments,” id. at
36, must be seen for what it is: an assertion that any president, now or in the future,
may hold such a boundless power nowhere is stated in law, any founding document,
or derived from our legal tradition.
The notion that the President’s judgment requires such limitless deference as
to be beyond judicial review is not borne out by the plain text of the statute. Section
12406 “permits the President to federalize the National Guard ‘[w]henever’ one of the
three enumerated conditions are met, not whenever he determines that one of them
is met.” D. Ct. Op. at 26 (quoting Newsom v. Trump, 786 F. Supp. 3d 1235, 1248 (N.D.
Cal. 2025) (quoting 10 U.S.C. § 12406) (emphasis in original)). Moreover, the nonreviewability argument fails to comport with the careful limitations the Founders
placed on the role of the military in domestic affairs and on the President’s power to
deploy federal military forces, which the district court detailed in its order. Id. at 14–
17. This is especially true in this context. Amici are concerned that reading the
statute to defer to any decision by the President to deploy troops in response to
protests by amici’s residents, in amici’s communities, and on amici’s streets—when
local law enforcement officials on the ground conclude military involvement is
unnecessary—completely negates local officials’ the expertise. And if and when local
law enforcement are overwhelmed, they can and do request federal resources,
10
including Guard troops, to complement local and state teams.8 See also Part I.B.,
infra.
The National Guard’s management of local protests usurps state and local
government’s constitutional interest to provide for the general welfare of their
residents through their police power. See, e.g., Walker v. Birmingham, 388 U.S. 307,
315 (1967) (“When protest takes the form of mass demonstrations, parades, or
picketing on public streets and sidewalks, the free passage of traffic and the
prevention of public disorder and violence become important objects of legitimate
state concern.”); San Francisco v. Trump, 783 F. Supp. 3d 1148, 1184 (N.D. Cal. 2025)
(citing San Francisco v. Trump, 897 F.3d 1225, 1234–36 (9th Cir. 2018)). Applicants
are undermining “localities’ right to sovereignty and self-determination [that] forms
the bedrock of our republic.” Id. This infringement on local sovereignty weighs
strongly against the public interest.
B.
The Public Interest Is Best Served When Local Law
Enforcement, Not Federalized Military Forces, Exercise Police
Powers to Ensure Public Safety and Manage Local Protests.
The vast majority of protests across the United States are peaceful.9 In the rare
circumstances when demonstrations threaten public safety, local law enforcement is
8 For example, in the wake of Hurricane Helene in 2024, National Guard troops
worked in coordination with state agencies to deal with the natural disaster. See C.
Todd Lopez, National Guard Provides Support to Hurricane Stricken States,
Department of War (Oct. 3, 2024), https://perma.cc/KTS7-ZEYZ.
9 See, e.g., Demonstrations and Political Violence in America: New Data for Summer
2020, ACLED (Sept. 3, 2020), https://perma.cc/8VD5-Z9D4 (finding 93% of national
demonstrations—in 2,400 locations—were peaceful).
11
better trained than military forces to handle such incidents. Unlike the National
Guard, which primarily serves to secure combat and natural disaster zones, local law
enforcement has extensive experience managing protests and deep understanding of
their communities. Amici, like Respondents, have established procedures and
training that endeavor to balance public safety, individual rights, the protection of
property, crowd management, preserving access to public space, and the preservation
of residents’ fundamental constitutional rights. Cf. Grider v. Abramson, 180 F.3d 739,
751–53 (6th Cir. 1999) (noting local governments have “significant public interests in
fostering the privileges of free expression and assembly” and in “the preservation of
community peace”). Moreover, the presence of the National Guard, combined with
aggressive tactics by federal agents, have only made it more challenging for local law
enforcement to fulfill its duties.
1.
Local law enforcement has specific expertise to respond to
protests and to de-escalate.
Local law enforcement officials are trained and prepared to make lawful
arrests when called for, and to de-escalate tensions during demonstrations and
protests, rather than inflaming them. The States’ National Guard lacks this
expertise. And to the extent that local law enforcement departments continue to
update and evolve their policies and practices to improve efficacy and trust in
communities, bringing in the federal military will not help those efforts. As one
retired military officer and expert explained: “Although [the National Guard] have
the mission of [responding to] domestic disturbances, they don't get a lot of training
in it, and they certainly don’t get the extensive training and the nuances that, for
12
example, the police get.”10
Here, the district court made factual findings that local law enforcement
officers in Chicago have competently managed crowds, related First Amendment
activity (including large scale protests), and ensured the ability of ICE officers to
enter and exit the Broadview ICE facility in the normal course of business. See D. Ct.
Op. at 3–9.11 Additionally, as seen in Chicago, local law enforcement do act to protect
federal personnel and facilities in collaboration with their federal counterparts when
their duties require it. The Court of Appeals’ conclusion that the statutory predicate
for deployment under Section 12406(3) has not been satisfied illustrates this point:
“Federal facilities, including the processing facility in Broadview, have remained
open despite regular demonstrations . . . And though federal officers have
encountered sporadic disruptions, they have been quickly contained by local, state,
and federal authorities.” App. Op. at 15 (emphasis added).
Amici’s local law enforcement agencies across the country have devoted
significant time to community engagement with the aim of building the public’s trust.
As a result, local law enforcement best understands which tactics might escalate a
situation in a particular community and what might be more useful in calming that
10 Alana Wise, The National Guard has Been Deployed to Enforce the Law Before.
What’s Different Now?, Nat’l Public Radio, (Aug. 21, 2025), https://perma.cc/7W7UZT9G.
11 By contrast, the district court noted that Applicants’ federal law enforcement
declarants have a “troubling” tendency to “equat[e] protests with riots and a lack of
appreciation for the wide spectrum that exists between citizens who are observing,
questioning, and criticizing their government, and those who are obstructing,
assaulting, or doing violence.” D. Ct. Op. at 10–11.
13
same community. These tactics are not window-dressing; they succeed in
deescalating serious conflicts.12
Military troops with no local orientation lack these critical insights. As the
district court concluded, “[t]o add to this milieu militarized actors unfamiliar with
local history and context whose goal is ‘vigorous enforcement’ of the law… is not in
the community’s interest.” D. Ct. Op. at 50–51 (cleaned up). The Court of Appeals
agreed, holding that “the public has a significant interest in having only well-trained
law enforcement officers deployed in their communities and avoiding unnecessary
shows of military force in their neighborhoods, except when absolutely necessary and
justified by law.” App. Op. at 17.
Critically, amici’s local law enforcement departments and individual officers
are directly accountable to the communities they serve, as they report ultimately to
elected mayors and city councils and in many cases are also subject to oversight from
citizen police commissions and boards. In contrast, federalized National Guard troops
are not directly accountable to the communities to which they are dispatched.
Turning to capacity, local governments like amici and Respondents have
established policies for coordinating responses to significant emergencies and civil
unrest when local resources prove to be insufficient. They allow local governments to
12
Pittsburgh Bureau of Police Roadway Safety Guidelines (July 26, 2018),
https://perma.cc/WB57-5TJP (detailing tactics Pittsburgh Police shall use to ensure
the safe flow of traffic during protests that affect roadways); see also Press Release,
City of New Haven, Statement by Mayor Elicker on Yale University Students Protest
and Successful De-escalation by the New Haven Police Department (Apr. 23, 2024),
https://perma.cc/897J-HJCV (describing, in statement from New Haven mayor,
successful deescalation of student protests).
14
request additional state and local resources in a practiced manner that will avoid
interagency conflicts, deescalate tensions, and prevent widespread disorder. See, e.g.,,
D. Ct. Op. at 5–6 (describing the Illinois law enforcement mutual aid network and
“Unified Command”). Centralized information-sharing and coordination of responses
within these groups avoids putting the public or law enforcement at risk, without the
need for any military forces.
In contrast, deploying military troops outside of established processes
heightens the likelihood of coordination failures and introduces more complexity and
risk for local law enforcement and the public. This is particularly true where the
Government deploys the National Guard in response to what the district court found
to typically be a small protest, rarely numbering more than fifty people and never
exceeding 200. D. Ct. Op. at 3; see also App. Op. at 3. For example, on the day before
the President’s announcement of a deployment, Broadview Police monitored a “small
crowd of quiet protestors” against whom ICE deployed tear gas, pepper spray, and
pepper balls. D. Ct. Op. at 5–6.
2.
The deployment of the National Guard has escalated
conflict and made it harder for local law enforcement to
do its job.
As the district court found, National Guard deployment itself is “likely to lead
to civil unrest, requiring deployment of state and local resources to maintain order.”
D. Ct. Op. at 49. This is not an unfounded supposition, as the Government suggests,
nor is it unique to Chicago. In fact, the escalation and intensification of protests in
response to threats and actual employment of the National Guard is an established
15
pattern. See Br. of Cal. and Gov. Newsom as Amici Curiae, D. Ct. ECF No. 40–1 at 6
(pointing out that, rather than quelling unrest, National Guard mobilization
inflamed further protests in Los Angeles, including spawning new unrest that
required more state resources);13 see also Op. & Order Granting TRO, Oregon v.
Trump, No. 25-cv-01756 (D. Or. Oct. 4, 2025), Dkt. No. 56 at 29 (noting that, on the
night of the Administration’s deployment announcement, “the size of protests
increased substantially” in Portland).14
Further, in Chicago, as some federal agents have become increasingly
aggressive in their response to protestors, Chicago police officers have faced
escalating on-the-job dangers, not just from rising tensions, but also from the tactics
employed by the federal agents. For instance, police stationed outside the Broadview
facility were recently tear gassed alongside protestors when ICE agents deployed the
gas.15 Given the increased militarization of these federal agencies and their use of
increasingly aggressive tactics, amici have a well-founded concern that National
13 On this point, Applicants suggest the Ninth Circuit in Newsom found that the
National Guard’s deployment in Los Angeles deterred further violence (see Gov. Br.
at 37), but the Court found no such thing, instead observing “that California's
concerns about escalation and interference with local law enforcement, at present,
are too speculative. We do not know whether future protests will grow due to the
deployment of the National Guard.” Newsom v. Trump, 141 F.4th 1032, 1054 (9th Cir.
2025).
14 See also Anna Griffin, In 2020, Trump Intervened in Portland’s Protests. They Got
Even Worse, N.Y. Times (Oct. 7, 2025), https://perma.cc/A7Z7-9LG2 (noting that
during the 2020 protests after George Floyd’s death, an influx of federal troops to
Portland prompted “tens of thousands of people” to protest).
15 Billal Rahman, ICE Accidentally Tear Gases Chicago Police During Clash With
Protesters, Newsweek (Oct. 6, 2025), https://perma.cc/CU3A-YWUK.
16
Guard troops, trained for military combat, will use disproportionate force in response
to protests, increasing the potential for tragic miscalculations and accidents.
The potential for disproportionate force is especially present because of the
extreme rhetoric the President has used in his public comments calling for
deployment of the National Guard. Among other things, the President has called
protesters the “enemy from within”16 and described Chicago as a “war zone.”17 The
Commander in Chief’s rhetoric cannot be dismissed as harmless, particularly as he
directs the deployment of armed military personnel and military weaponry to amici’s
streets.18 Cities and local governments like amici, and their residents, have a strong
interest in preventing escalations of violence.
The tactics used by federal law enforcement on local residents in Broadview
have also resulted in additional costs and resource expenditures for Respondents. See
D. Ct. Op. at 49–50. The district court noted the “provocative nature of ICE’s
enforcement activity” has caused a corresponding uptick in protests, which state and
local law enforcement agencies respond to. Id. at 49. The resulting “diversion of
limited state and local resources is an irreparable harm.” Id. at 50; cf. Swain v.
Junior, 958 F.3d 1081, 1090 (11th Cir. 2020) (finding irreparable harm because
16 President Donald Trump, supra n.2.
17 President Donald Trump, Speech on Signing Executive Order on Alaskan Energy
and Minerals in Washington, D.C. (Oct. 6, 2025), (transcript available via Roll Call,
https://perma.cc/B7JE-MZXL).
18 As the retired military general explained: “The military mindset is wrong…The
police look at the people in front of them as citizens who may be misbehaving, but
they're citizens. The military looks at people out there and sees threats that need to
be neutralized, and that can lead to bad things.” Wise, supra n.10.
17
government officials “will lose the discretion . . . to allocate scarce resources among
different county operations necessary to fight the pandemic”). The deployment of the
National Guard is likely to increase these costs by further increasing the need for
local law enforcement presence if the size and intensity of protests and dispersion
tactics increase. Amici, like Respondents, manage limited local resources, and share
a critical public interest in avoiding the unnecessary expenditures and strain on local
law enforcement that accompanies military deployment.
C.
Actual and Threatened Militarization of Our Cities Disturbs Our
Residents’ Well-Being and Our Local Economies.
Federal military presence, when deployed without cause, damages amici’s
communities psychologically and economically. Far from feeling safer, residents
report that federal soldiers’ occupancy of their cities causes anxiety, disrupts
community harmony, and damages the local economy.19
Internal documents suggest that federal military leaders are aware that the
Government’s actions are perceived as “leveraging fear,” driving a “wedge between
citizens and the military.”20 Experts note that the presence of troops in neighborhoods
increases individuals’ perception of danger, not security.21 Rather than strengthening
19 Joshua Chapin, Downtown DC Businesses Hope for Increased Foot Traffic After
End To Federal Takeover, ABC 7 News (Sept. 11, 2025), https://perma.cc/HGX5G7RQ (noting drop in foot traffic in downtown Washington, D.C. after deployment of
troops).
20 Alex Horton, National Guard Documents Show Public ‘Fear,’ Veterans ‘Shame’
Over D.C. Presence, Wash. Post (Sept. 10, 2025), https://perma.cc/S5QX-8VNB.
21 Ed White & Christopher L. Keller, Trump’s Push for More Troops in US Cities at
Odds with Crime Stats, Military Times (Aug. 29, 2025), https://perma.cc/2RVTE7GK.
18
trust, applicants threaten to unravel decades of work that amici have invested in
building trust with our communities. This is especially true when the federal troop
deployments occur against the backdrop of the President’s hostile rhetoric and public
statements that demean the capacity of local leaders.22
Sending the National Guard to cities in response to demonstrations and
alleged general crime will also cause local economies to suffer. Like City Respondent,
amici represent local governments which depend on tax revenue generated by local
businesses. See Mem. Supp. Pls.’ Mot. for TRO, D. Ct. Dkt. No. 13 at 48. Many amici
rely upon tourism as a top generator of economic stability. Evidence shows that the
National Guard presence in Washington D.C. and Los Angeles has caused abrupt
declines in tourism,23 restaurants have also lost business,24 and major community
events have reduced attendance.25 Moreover, as discussed, the unnecessary
deployment of federal law enforcement to American cities has historically provoked
heightened civil unrest, which can exacerbate economic losses. Negative effects from
the deployments are not confined—and surrounding counties also feel the effects. The
22 Megan Lebowitz, Trump Says Gov. JB Pritzker and Chicago Mayor Brandon
Johnson 'Should be in Jail', NBC News (Oct. 8, 2025), https://perma.cc/5WJDKWFT.
23 See Schwalb Decl., D.C. v. Trump, No. 25-cv-3005 (D.D.C. 2025), Dkt. No. 3-5, at ¶
¶7, https://perma.cc/BZ7A-8LDW; Mimi Montgomery, Trump Crackdown is Affecting
D.C.’s Image and Tourism Numbers, Axios D.C. (Aug. 29, 2025),
https://perma.cc/CR64-X3JY.
24 Milton Guevara, How National Guard Troops in D.C. Are Affecting Restaurants in
the Capital, Nat’l Public Radio (Sept. 1, 2025), https://perma.cc/6AU5-HENA.
25 Andrea Sachs & Federica Cocco, D.C. Tourism Was Already Struggling, Then the
National Guard Arrived, Wash. Post (Aug. 29, 2025), https://perma.cc/BRG6-4D7T.
19
fear and confusion caused by deployment in Los Angeles, for example, spilled over to
neighboring Santa Ana, where a “large part of the community stays home in fear,”
depressing economic activity.26
Local economies are likely to be affected not only by the presence of National
Guard troops, but also by reputational injury associated with the President’s
opprobrium that accompanies such deployment. The President has oscillated in his
public justifications for deploying the National Guard; in some instances, he has
advanced his belief that deployment is warranted to participate in regular policing.
For instance, the Administration has authorized deployment of Guard troops to
Washington D.C. and Memphis, Tennessee, to address what the President
characterizes as widespread crime in those cities.27 Likewise, the President’s military
deployment threats directed at other amici are based on his unfounded and partisan
assertions that those cities are “very bad.”28 Even if untethered from the reality on
the ground, the deployment unfairly and falsely validates the President’s assertions
that these cities are crime-ridden and unsafe, harming their reputation and appeal
26
Immigration Raids and Military Presence Hurting Economy in Santa Ana,
Employees Say, ABC 7 News (Jun. 11, 2025), https://perma.cc/NFP8-7E3B.
27 See Memorandum on Restoring Law and Order in Memphis (Sept. 15, 2025),
https://perma.cc/3MUP-8FBQ; see also Memorandum on Restoring Law and Order
in the District of Columbia, (Aug. 11, 2025), https://perma.cc/2YEC-4UD4.
28 Trump Hints He Could Send National Guard to Oakland, Fox KTVU (Aug. 12,
2025), https://perma.cc/QGT4-V755.
20
to visitors.29 By first casting these aspersions, and then deploying military personnel
to these cities, the President inflicts serious reputational and concomitant economic
harm.
The President also has suggested potential disruption of future international
events—for which amici already have expended significant resources—under the
guise of public safety concerns. For example, the President mused about relocating
the World Cup from Boston, stating: “[T]hey’re taking over parts of Boston…we’ll go
in and take them back…if I feel there’s unsafe conditions … I would say, let’s move it
to another location…I could say the same thing for the Olympics.”30
Amici are further harmed by the President’s ongoing and planned deployment
of National Guard troops because members of the National Guard are also residents
of amici’s communities. They hold jobs, raise their families, and contribute to amici’s
social fabric. Many deployed Guard members are missing family milestones and
work, all while expressing shame about their present mission.31 Hundreds of
members of the National Guard have left their families and local communities to
travel hundreds of miles for an unlawful mission in Chicago. They are spending
29 See Antje Blinde et al., International Travelers Are Growing Skeptical of the U.S.,
Spiegel Int’l, (June 19, 2025), https://perma.cc/26GH-JJJX (documenting a drop of
international tourism, and associated revenue and employment, to the U.S. and
explaining that the Trump administration’s policies, as well as his “aggressive
assault against relatively harmless demonstrations…send[] a clear message to the
world: If you aren’t with me, you are against me.”).
30 President Donald Trump, Remarks During Bilat with Javier Melei of Argentina
in Washington, D.C. (Oct. 14, 2025) (transcript available via Roll Call,
https://perma.cc/ATU9-GKDE).
31 Horton, supra n.20.
21
weeks at a government facility based on a version of the facts that the district court,
after a thorough review of the record, found to be “inaccurate” and justified by
“unreliable information.” D. Ct. Op. at 9–11. And, if the current government
shutdown continues, they will soon be doing so without pay.32 At the same time,
taxpayers are paying the massive price of these deployments—approximately $400
million for D.C., $134 million for Los Angeles, and an initial estimate of $10 million
for Oregon.33
CONCLUSION
Amici, representing tens of millions of Americans, have a fundamental interest
in ensuring that these unnecessary deployments cease and that the rule of law is
restored. The public interest overwhelmingly supports maintaining the status quo,
and this Court should deny the Government’s application for a stay.
32 Meredith Lee Hill & Jennifer Scholtes, Trump’s troop pay move is a ‘temporary
fix,’ Johnson says, Politico (Oct. 15, 2025), https://perma.cc/C8RE-BSR2.
33 Noah Robertson, LA Deployments to Cost $134 Million and Last 60 Days, Pentagon
Says, Military Times (June 10, 2025), https://perma.cc/2N6D-ZPWH; Andrew
Schwartz, National Guard Deployment—Estimated Cost: $10 Million—Crawls Along,
Willamette Week (Oct. 1, 2025), https://perma.cc/Z9X8-ZX8W; Melody Gutierrez,
Trump’s Military Deployment in L.A. Cost $120 Million, Newsom Says, LA Times
(Sept. 4, 2025), https://perma.cc/H3FE-E9FC; see also Marc Novicoff, A Very, Very
Expensive Way to Reduce Crime, The Atlantic (Oct. 10, 2025), https://perma.cc/LH3D9CFB.
22
Dated: October 20, 2025
Respectfully submitted,
JENNY S. MA
Counsel of Record
JONATHAN B. MILLER
JEAN LARSEN
PUBLIC RIGHTS PROJECT
490 43rd Street, #115
Oakland, CA 94609
Telephone: (510) 738-6788
Attorneys for Amici Curiae
23
ADDITIONAL COUNSEL
YIBIN SHEN
City Attorney
2263 Santa Clara Avenue, Room 280
Alameda, CA 94501
Attorney for the City of Alameda,
California
EBONY M. THOMPSON
City Solicitor
Baltimore City Department of Law
100 North Holliday Street
Baltimore, MD 21202
Attorney for the City of Baltimore,
Maryland
ROBERT MAGEE
Corporation Counsel
24 Eagle Street, Room 106
Albany, NY 12207
Attorney for the City of Albany, New
York
ADAM CEDERBAUM
Corporation Counsel
One City Hall Square, Room 615
Boston, MA 02201
Attorney for the City of Boston,
Massachusetts
LAUREN KEEFE
City Attorney of Albuquerque
One Civic Plaza, 4th Floor
Albuquerque, NM 87102
Attorney for the City of Albuquerque,
New Mexico
JESSICA C. BROWN
City Attorney
Office of City Attorney & Corporation
Counsel
149 Church Street
Burlington, VT 05401
Attorney for the City of Burlington,
Vermont
CHERAN IVERY
City Attorney
301 King Street, Suite 1300
Alexandria, VA 22314
Attorney for the City of Alexandria,
Virginia
MEGAN BAYER
City Solicitor
795 Massachusetts Avenue
Cambridge, MA 02139
Attorney for the City of Cambridge,
Massachusetts
ROSALYN GUY-MCCORKLE
Allegheny County Solicitor
445 Fort Pitt Boulevard, Suite 300
Pittsburgh, PA 15219
Attorney for County of Allegheny,
Pennsylvania
CARLOS PABELLON
Corporation Counsel
DAVID R. GAULT
Deputy Corporation Counsel
Room 419, City-County Building
210 Martin Luther King, Jr.,
Boulevard
Madison, WI 53703
Attorneys for County of Dane,
Wisconsin
ATLEEN KAUR
City Attorney
Guy C. Larcom City Hall
301 East Huron, 3rd Floor
Ann Arbor, MI 48104
Attorney for the City of Ann Arbor,
Michigan
24
MIKO BROWN
City Attorney
1437 Bannock Street, Room 353
Denver, CO 80202
Attorney for the City and County of
Denver, Colorado
MICHAEL HAAS
City Attorney
210 Martin Luther King Jr. Blvd.,
Room 401
Madison, WI 53703
Attorney for the City of Madison,
Wisconsin
LEESA MANION
Prosecuting Attorney
Chinook Building
401 5th Avenue, Suite 800
Seattle, WA 98104
Prosecuting Attorney for Martin
Luther King, Jr. County
KRISTYN ANDERSON
City Attorney
350 South 5th Street
Minneapolis, MN 55415
Attorney for the City of Minneapolis,
Minnesota
DAWN MCINTOSH
City Attorney
411 West Ocean Boulevard, 9th Floor
Long Beach, CA 90802
Attorney for the City of Long Beach,
California
SUSAN K. BLITCH
County Counsel
188 West Alisal Street, 3rd Floor
Salinas, CA 93901
Attorney for the County of Monterey,
California
HYDEE FELDSTEIN SOTO
City Attorney
200 North Main Street, 8th Floor
Los Angeles, CA 90012
Attorney for the City of Los Angeles,
California
JOHN P. MARKOVS
Montgomery County Attorney
101 Monroe Street, 3rd Floor
Rockville, MD 20850
Attorney for Montgomery County,
Maryland
JUDY W. WHITEHURST
Chief Deputy
LILIANA CAMPOS
Assistant County Counsel
BRIGIT GREESON ALVAREZ
Deputy County Counsel
648 Kenneth Hahn Hall of
Administration
500 West Temple Street
Los Angeles, CA 90012-2713
Attorneys for the County of Los Angeles
JENNY MADKOUR
County Attorney
501 Southeast Hawthorne Boulevard,
Suite 500
Portland, OR 97214
Attorney for Multnomah, Oregon
PATRICIA KING
Corporation Counsel
165 Church Street
New Haven, CT 06510
Attorney for the City of New Haven,
Connecticut
25
MURIEL GOODE-TRUFANT
Corporation Counsel
100 Church Street
New York, NY 10007
Counsel for the City of New York, New
York
PATRICK BEATH
Corporation Counsel
30 Church Street, Room 400A
Rochester, New York 14614
Attorney for the City of Rochester, New
York
ALAN SEEWALD
City Solicitor
One Roundhouse Plaza, Suite 304
Northampton, MA 01060
Attorney for the City of Northampton,
Massachusetts
SUSANA ALCALA WOOD
City Attorney
915 I Street, 4th Floor
Sacramento, CA 95814
Attorney for City of Sacramento,
California
RYAN RICHARDSON
City Attorney
One Frank H. Ogawa Plaza, 6th Floor
Oakland, CA 94612
Attorney for the City of Oakland,
California
LYNDSEY M. OLSON
City Attorney
400 City Hall & Court House
15 West Kellogg Boulevard
St. Paul, MN 55102
Attorney for the City of St. Paul,
Minnesota
LAURA CONOVER
County Attorney
Pima County Attorney’s Office
32 North Stone Avenue
Tucson, AZ 85745
Attorney for Pima County, Arizona
HEATHER FERBERT
San Diego City Attorney
1200 3rd Avenue, Suite 1100
San Diego, CA 92101
Attorney for the City of San Diego,
California
KRYSIA KUBIAK
City Solicitor and Chief Legal Officer
414 Grant Street
Pittsburgh, PA 15219
Attorney for the City of Pittsburgh,
Pennsylvania
NORA FRIMANN
City Attorney
200 East Santa Clara Street,
16th Floor
San José, CA 95113
Attorney for the City of San José,
California
ROBERT TAYLOR
City Attorney
1221 Southwest Fourth Avenue,
Room 430
Portland, OR 97204
Counsel for the City of Portland,
Oregon
TONY LOPRESTI
County Counsel
70 West Hedding Street East Wing,
9th Floor
San José, CA 95110
Attorney for County of Santa Clara,
California
26
JOHN D. NIBBELIN
County Counsel
400 County Center, 6th Floor
Redwood City, CA 94063
Attorney for San Mateo County,
California
DAVID CHIU
City Attorney
City Hall Room 234
One Dr. Carlton B. Goodlett Place
San Francisco, CA 94102
Attorney for the City and County of
San Francisco, California
HEIDI VON TONGELN
Interim City Attorney
1685 Main Street, Room 310
Santa Monica, CA 90401
Attorney for the City of Santa Monica,
California
ROI LUSK
City Attorney
PO Box 27210
Tucson, AZ 85726-7210
Attorney for the City of Tucson,
Arizona
LAUREN LANGER
City Attorney
Best Best & Krieger LLP
300 South Grand Avenue, 25th Floor
Los Angeles, CA 90071
Attorney for City of West Hollywood,
California
27
Appendix A – List of Amici Curiae
Local Governments
City of Alameda, California
City of Albany, New York
City of Albuquerque, New Mexico
City of Alexandria, Virginia
Allegheny County, Pennsylvania
City of Anaheim, California
City of Ann Arbor, Michigan
City of Baltimore, Maryland
City of Boston, Massachusetts
City of Burlington, Vermont
City of Cambridge, Massachusetts
Dane County, Wisconsin
City and County of Denver, Colorado
City of Evanston, Illinois
King County, Washington
City of Long Beach, California
City of Los Angeles, California
Los Angeles County, California
City of Madison, Wisconsin
City of Minneapolis, Minnesota
28
Monterey County, California
Montgomery County, Maryland
Multnomah County, Oregon
City of Newark, New Jersey
City of New Haven, Connecticut
City of New York, New York
City of Northampton, Massachusetts
City of Oakland, California
Pima County, Arizona
City of Pittsburgh, Pennsylvania
City of Portland, Oregon
City of Rochester, New York
City of Sacramento, California
City of St. Paul, Minnesota
City of San Diego, California
City of San José, California
County of Santa Clara, California
San Mateo County, California
City of Santa Monica, California
City and County of San Francisco, California
Sonoma County, California
City of Tucson, Arizona
29
City of West Hollywood, California
Local Government Leaders
Luis Alejo
Supervisor, County of Monterey, California
Valarie Bachelor
School Board Director, City of Oakland, California
Jorge Baron
Councilmember, King County, Washington
Ravinder Bhalla
Mayor, City of Hoboken, New Jersey
Jesse Brown
Councilmember, City of Indianapolis, Indiana
Xouhoa Bowen
Vice Mayor, City of San Leandro, California
Chelsea Byers
Mayor, City of West Hollywood, California
Barb Byrum
Clerk, Ingham County, Michigan
Chris Canales
Councilmember, City of El Paso, Texas
Michael Chameides
Supervisor, County of Columbia, New York
John Clark
Mayor, Town of Ridgway, Colorado
Laura Conover
County Attorney, County of Pima, Arizona
30
Christine Corrado
Councilmember, Town of Brighton, New York
Olgy Diaz
Councilmember, City of Tacoma, Washington
Roger Dickinson
Councilmember, City of Sacramento, California
Michael Dougherty
20th Judicial District Attorney, Colorado
Justin Douglas
Commissioner, Dauphin County, Pennsylvania
Diane Ellis-Marseglia
Commissioner, Bucks County, Pennsylvania
Marilyn Ezzy Ashcraft
Mayor, City of Alameda, California
Ramin Fatehi
Commonwealth's Attorney, City of Norfolk, Virginia
Bryan “Bubba” Fish
Councilmember, City of Culver, California
Vanessa Fuentes
Mayor Pro Tem, City of Austin, Texas
Brenda Gadd
Councilmember, Metropolitan Nashville & Davidson County, Tennessee
Adrian Garcia
Commissioner, County of Harris, Texas
Heidi Garrido
Councilmember, City of Hopkins, Minnesota
31
Megan Green
President of Board of Alderman, St. Louis County, Missouri
Marquette Green-Scott
Mayor Pro Tem, Iowa Colony, Texas
Jonathan Guzmán
School Committee Vice-Chair, City of Lawrence, Massachusetts
Beau Harbin
Legislator, County of Cortland, New York
Robert J. Harvie
Commissioner, Bucks County, Pennsylvania
Jani Hitchen
Councilmember, County of Pierce County, Washington
Stephanie Howse-Jones
Councilmember, City of Cleveland, Ohio
Susan Hughes-Smith
Legislator, County of Monroe, New York
Christopher Jaramillo
Norristown Area School District Board President, County of Montgomery,
Pennsylvania
Lisa Kaplan
Councilmember, City of Sacramento, California
Lisa Lawitzke
Clerk, Town of Bellevue, Michigan
Jerald Lentini
Director, Town of Manchester, Connecticut
32
Sarah Leonardi
School Board Member, Broward County, Florida
Jessie Lopez
Councilmember, City of Santa Ana, California
Quinton D. Lucas
Mayor, City of Kansas, Missouri
Kim Lund
Mayor, City of Bellingham, Washington
Christian Menefee
County Attorney, Harris County, Texas
William Moehle
Supervisor, Town of Brighton, New York
Steve Mulroy
District Attorney, County of Shelby, Tennessee
Arnetta Murray
Councilmember, City of Iowa Colony, Texas
Linda Mussmann
Supervisor, City of Hudson, New York
Jonathan Nieuwsma
Councilmember, City of Evanston, Illinois
Isabel Piedmont-Smith
Councilmember, City of Bloomington, Illinois
Veronica Pillar
Legislator, Tompkins County, New York
Jacqueline “Jack” Porter
Commissioner, City of Tallahassee, Florida
33
Delishia Porterfield
Councilmember, Metropolitan Nashville & Davidson County, Tennessee
Satya Rhodes-Conway
Mayor, City of Madison, Wisconsin
Ryan Richardson
City Attorney, City of Oakland, California
Amanda Rodriguez
Councilmember, City of San Marcos, Texas
Rossana Rodríguez Sánchez
Alderperson, City of Chicago, Illinois
Miguel Sanchez
Councilmember, City of Providence, Rhode Island
Dawn Marie Sass
Clerk/Deputy Treasurer, City of Exeter, Wisconsin
Eli Savit
Prosecuting Attorney, Washtenaw County, Michigan
Gina-Louise Sciarra
Mayor, City of Northampton, Massachusetts
Michael Siegrist
Clerk, Town of Canton, Michigan
Seema Singh
Councilmember, City of Knoxville, Tennessee
David Stout
Commissioner, City of El Paso, Texas
Lena Tam
Supervisor, County of Alameda, California
34
Terry Vo
Councilmember, Metropolitan Nashville & Davidson County, Tennessee
Braxton White
Commissioner, County of Clarion, Pennsylvania
Robin Wilt
Councilmember, Town of Brighton, New York
35
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.