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United States Immigration and Customs Enforcement (“ICE”) significantly relies on state and local personnel and resources to carry out enforcement of immigration law. California Senate Bill 54 (“SB 54”), the “California Values Act,” is California’s attempt to disentangle local law enforcement from federal civil immigration enforcement.

This Article offers an in-depth evaluation of SB 54’s mechanics; identifies vulnerabilities that exist despite SB 54 and potential means for law enforcement agencies (“LEAs”) to combat these issues; and comments on how local individual LEAs and the California Department of Corrections and Rehabilitation have chosen to exercise the discretion to comply (or not comply) with immigration hold/detainer requests from the federal government, as well as information and data-sharing requests, within the framework of SB 54. The constitutionality of SB 54 is not the focus of this Article, rather, the focus is on the myriad of issues implicated in California's attempts to restrict cooperation and communication with federal immigration enforcement. SB 54 provides a strong framework for accomplishing these goals, but nonetheless remains vulnerable to exploitation, such as LEAs making release dates publicly available, and falls short in addressing overarching issues such as ICE access to law enforcement databases. †

Publication Date



United States Immigration and Customs Enforcement, California Senate Bill 54


Immigration Law | Law


Article to be published in the Berkeley Asian American Law Journal.

California Divided: The Restrictions and Vulnerabilities in Implementing SB 54, 26 Asian Am. L.J. ___ (forthcoming in 2019).



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