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City of Chicago v. Barr

961 F.3d 882 (2020)

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City of Chicago v. Barr

United States Court of Appeals for the Seventh Circuit
961 F.3d 882 (2020)

Facts

Byrne Justice Assistance Grants (JAG grants) provided federal funding to support state and local law enforcement. The annual grants were determined using a formula under which the award amounts to each state and local government were interdependent. For JAG grants in 2017, the attorney general attached certain conditions to the receipt of funding. Specifically, a state or local government was required to (1) notify federal immigration authorities when noncitizens were released from custody, (2) give federal agents access to noncitizens while in custody, and (3) comply with a federal law prohibiting local governments from stopping their officials from communicating immigration information to federal authorities. For 2018 grants, the receipt of funding was subject to similar conditions. The 2017 and 2018 conditions conflicted with an ordinance of the City of Chicago (Chicago) (plaintiff), prompting Chicago to sue Attorney General William Barr (defendant) to challenge their imposition. The district court concluded that the conditions were facially unlawful and issued an injunction prohibiting the conditions’ imposition as to all applicants for JAG grants. Barr appealed, arguing, among other things, that the district court erred in granting a universal injunction that extended relief beyond Chicago, the specific complainant in the suit.

Rule of Law

Issue

Holding and Reasoning (Rovner, J.)

Concurrence (Manion, J.)

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