Arpaio v. Obama
2014 U.S. Dist. LEXIS 176758
D.D.C.2014Background
- Joe Arpaio, elected Sheriff of Maricopa County, sued the President and federal officials challenging three DHS deferred-action programs (DACA, 2014 DACA revisions, and DAPA) announced in 2012 and November 20, 2014, seeking injunction and declaratory relief.
- Deferred action: longstanding executive enforcement tool allowing DHS to decline removal for limited periods; does not confer legal status and is revocable. DHS uses deferred action to prioritize limited removal resources.
- DACA (2012) permits case-by-case two-year deferred action for certain people brought to U.S. as children; 2014 revisions expanded eligibility and extended duration. DAPA (2014) permits three-year deferred action for certain parents of U.S. citizens or lawful permanent residents meeting specific criteria.
- Arpaio alleged injuries to his office (financial burdens, increased workload, public-safety impacts) and threatened personal targeting; he sued in both individual and official capacities.
- Defendants moved to dismiss for lack of subject-matter jurisdiction (no Article III standing); the court held a hearing and permitted supplemental filings before ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing to challenge federal deferred-action programs | Arpaio: federal programs increase illegal immigration, imposing concrete financial and operational burdens on his sheriff's office and threaten him personally | Defendants: alleged harms are speculative, arise from independent third-party conduct (immigrants), and are not fairly traceable or redressable by enjoining DHS programs | Court: No standing — injuries are generalized or speculative; causation and redressability fail; dismissal for lack of jurisdiction |
| Personal-capacity standing based on threats | Arpaio: press reports show assassination threats tied to his immigration stance, giving him imminent injury | Defendants: threats are past or not shown to be ongoing or causally connected to programs; relief would not redress threat | Court: No personal standing — threats not linked to challenged programs and not redressable |
| Official-capacity standing based on burdens to county resources | Arpaio: deferred-action programs force county to bear costs of immigrants (jail, enforcement) — concrete official injury | Defendants: Arpaio lacks authority to enforce federal immigration law; alleged burdens are generalized, speculative, and not caused by the programs (which apply to residents before 2010) | Court: No official standing — injury is generalized/speculative and not fairly traceable or redressable |
| Entitlement to preliminary injunction | Arpaio: injunction needed to prevent irreparable harm and enforcement beyond Congress’s intent | Defendants: Arpaio lacks standing; programs are longstanding prosecutorial discretion consistent with statutes; injunctive factors not met | Court: Denied preliminary injunction — no likelihood of success (standing fails), no irreparable harm, and public interest disfavors injunction |
Key Cases Cited
- Arizona v. United States, 567 U.S. 387 (2012) (federal political branches have primary authority over immigration enforcement)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (three-part Article III standing test)
- Defenders of Wildlife v. Lujan, 504 U.S. 555 (1992) (limits on standing when injury depends on third-party actions)
- Valley Forge Christian College v. Americans United for Separation of Church & State, 454 U.S. 464 (1982) (courts should not adjudicate generalized grievances)
- Heckler v. Chaney, 470 U.S. 821 (1985) (agency prosecutorial discretion and nonenforcement decisions)
- Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (standards for issuing preliminary injunctions)
- Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579 (1952) (presidential power framework)