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Arizona v. United States

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Arizona v. United States
NameArizona v. United States
CourtSupreme Court of the United States
DateJune 25, 2012
Citation567 U.S. 387
PriorOn appeal from the United States Court of Appeals for the Ninth Circuit

Arizona v. United States. The case involved a challenge to the Arizona Senate's passage of Support Our Law Enforcement and Safe Neighborhoods Act, also known as SB 1070, which was signed into law by Jan Brewer, the Governor of Arizona, on April 23, 2010. The law was aimed at reducing illegal immigration in Arizona by granting Arizona State Police and other law enforcement agencies the authority to stop and arrest individuals suspected of being in the United States without proper documentation, in accordance with Title 8 of the United States Code. The law also made it a state crime for individuals to fail to carry alien registration documents and for undocumented immigrants to seek or engage in work in Arizona, as stated in the Immigration and Nationality Act and the Omnibus Budget Reconciliation Act of 1986.

Background

The Support Our Law Enforcement and Safe Neighborhoods Act was enacted in response to concerns about the impact of illegal immigration on Arizona's economy, public safety, and natural resources, as discussed by John McCain, Jon Kyl, and other members of the United States Senate Committee on the Judiciary. The law's provisions were designed to work in conjunction with federal immigration law, including the Immigration and Nationality Act, and to provide additional tools for Arizona law enforcement agencies to address the issue of illegal immigration, as outlined in the Secure Fence Act of 2006 and the REAL ID Act of 2005. However, the law was met with opposition from various groups, including the American Civil Liberties Union, the National Council of La Raza, and the Mexican American Legal Defense and Educational Fund, who argued that it would lead to racial profiling and violate the Fourth Amendment to the United States Constitution and the Fourteenth Amendment to the United States Constitution, as interpreted by the United States Court of Appeals for the Ninth Circuit in Gonzales v. City of Peoria.

The United States Department of Justice filed a lawsuit against the state of Arizona in the United States District Court for the District of Arizona, challenging the constitutionality of SB 1070 and seeking a preliminary injunction to block its implementation, as authorized by the Declaratory Judgment Act and the Federal Rules of Civil Procedure. The case was heard by Judge Susan Bolton, who granted the injunction, ruling that certain provisions of the law were likely to be preempted by federal law, including the Immigration and Nationality Act and the Omnibus Budget Reconciliation Act of 1986, as amended by the Immigration Act of 1990 and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996. The state of Arizona appealed the decision to the United States Court of Appeals for the Ninth Circuit, which upheld the injunction, citing the Supremacy Clause of the United States Constitution and the McCarran-Walter Act.

Supreme Court Decision

The Supreme Court of the United States granted certiorari and heard oral arguments in the case on April 25, 2012, with Solicitor General Donald Verrilli arguing on behalf of the United States Department of Justice and Paul Clement arguing on behalf of the state of Arizona, as reported by SCOTUSblog and the National Law Journal. On June 25, 2012, the Court issued its decision, striking down three provisions of SB 1070 as preempted by federal law, including the Immigration and Nationality Act and the Omnibus Budget Reconciliation Act of 1986, while upholding the provision that allowed Arizona State Police to check the immigration status of individuals stopped or arrested for other reasons, as authorized by the Secure Communities program and the 287(g) program. The decision was written by Justice Anthony Kennedy and joined by Chief Justice John Roberts, Justice Ruth Bader Ginsburg, Justice Stephen Breyer, and Justice Sonia Sotomayor, with Justice Antonin Scalia, Justice Clarence Thomas, and Justice Samuel Alito dissenting, as noted by The New York Times and the Los Angeles Times.

Impact and Aftermath

The decision in Arizona v. United States had significant implications for the debate over immigration reform in the United States, with many advocates for comprehensive immigration reform citing the decision as evidence of the need for a federal solution to the issue, as discussed by Barack Obama, John Boehner, and other members of the United States Congress. The decision also led to increased scrutiny of other state and local laws aimed at addressing illegal immigration, including laws in Alabama, Georgia, and South Carolina, as reported by the National Conference of State Legislatures and the Pew Research Center. In the aftermath of the decision, the United States Department of Homeland Security announced that it would be suspending the 287(g) program in Arizona and would no longer accept Secure Communities requests from the state, as stated in a letter from Janet Napolitano to Jan Brewer.

Constitutional Implications

The decision in Arizona v. United States highlighted the ongoing debate over the balance of power between the federal government and the states in the area of immigration law, with some arguing that the decision represented an overreach of federal authority and others arguing that it was necessary to ensure that the federal government's plenary power over immigration was not undermined, as discussed by Alexander Hamilton, James Madison, and other Founding Fathers in The Federalist Papers. The decision also raised questions about the implications of the Tenth Amendment to the United States Constitution and the Supremacy Clause for the relationship between the federal government and the states, as interpreted by the Supreme Court of the United States in McCulloch v. Maryland and Garcia v. San Antonio Metropolitan Transit Authority. As the debate over immigration reform continues, the decision in Arizona v. United States is likely to remain an important precedent, as noted by The Washington Post and the Wall Street Journal. Category:United States Supreme Court cases