[U] Echoing Many Of My Themes, At Least 18 Cities Have Filed An Amicus Brief Against Trump's Unlawful Proposed Unlicensed Detention "Rules"

UPDATED -- 11.17.18 @ 11 AM EST: Here is a fine additional brief (just filed overnight), from the AM Law 100 Orrick firm, on why Trump is. . . wrong, here. End, update.

And again, I am in the ACLU's debt, for my comments to the proposed rulemaking -- and the fine amici clearly are as well. They have put a lot more meat on the bones of the arguments, though -- citing each of the cities' long experience protecting kids in LICENSED care facilities.

Without additional ado, here is a bit of the 30 page PDF of the well-reasoned overnight brief, in Flores:

. . . .Many amici, like the City of Los Angeles, Los Angeles County, the City of New York and the City and County of San Francisco all prosecute violations of child welfare laws and health and safety codes in their respective jurisdictions. Cases are routinely referred to these offices for prosecution by the State of California’s and the State of New York’s licensing agencies. And in addition to enforcing state laws, some amici have local ordinances requiring state-licensed facilities to abide by local fire, building, and other safety codes that ensure the safety not only of the children, but also of the staff and first responders.

For example, Chicago’s and Los Angeles’s municipal codes subject state-licensed child care institutions to additional oversight, inspections, and penalties beyond those provided for by the State of Illinois and State of California, respectively. See Chicago Mun. Code § 4-76-010 et seq.; Los Angeles Mun. Code § 57.105.3.9.2.1, 57.105.6.24. These state licensing schemes and local laws reflect amici’s interests in ensuring protection for immigrant children – protections that will not necessarily exist for children housed in federally-“licensed” facilities. . . .

This notion, that 45 can just malevolently "make unlawful sh!t up" -- as he goes along -- must end, especially when (as here) the safety of children hangs in the balance. Onward -- enraged.

नमस्ते