## Facts

- California voters approved Proposition 187 (the “Save Our State” initiative) in November 1994.
- The measure sought to restrict access to state-funded public benefits for persons not lawfully present in the United States and imposed verification and reporting duties on state and local officials.
- It required law-enforcement, social-services, health-care, and public-education personnel to verify immigration status in covered circumstances, provide specified notices, report suspected unlawful presence to state and federal authorities, and deny specified services based on those determinations.
- In public education, it directed schools to verify the immigration status of students and parents, report suspected unlawful presence, and take steps aimed at transitioning children to schools outside the United States.
- Civil-rights organizations and individual plaintiffs filed consolidated federal actions seeking declaratory and injunctive relief to block enforcement of the initiative against state officials responsible for implementation.
- After preliminary injunctions against major provisions, the case proceeded on cross-motions for summary judgment and requests for permanent injunctive relief.

## Issues

1. Whether Proposition 187’s verification, reporting, and benefit-denial scheme was preempted by federal immigration law under the Supremacy Clause (field and conflict preemption).
2. Whether the initiative constituted an impermissible state regulation of immigration by creating state-level immigration status determinations and enforcement mechanisms.
3. Whether specific provisions conflicted with federal statutes and federal policy choices governing immigration enforcement and noncitizen eligibility for public benefits and services.

## Decision

- The court granted summary judgment for the plaintiffs as to the core operative provisions of Proposition 187.
- Applying the preemption framework associated with De Canas v. Bica, the court concluded that key portions either regulated immigration directly or conflicted with federal immigration law and objectives.
- The court declared substantial portions of the initiative unconstitutional under the Supremacy Clause and permanently enjoined their enforcement.
- The court treated the initiative section-by-section and invalidated provisions central to immigration-status verification, mandated reporting, and denial of covered services, including provisions directed at schools and other public institutions.

## Legal Principles

- Federal authority over immigration and the status of noncitizens is primary and often exclusive; state measures that create parallel immigration enforcement systems are subject to Supremacy Clause limits.
- Under the De Canas preemption analysis, a state law is invalid if it (1) constitutes a regulation of immigration, (2) is preempted because Congress has occupied the field, or (3) conflicts with federal law or stands as an obstacle to congressional objectives.
- Conflict preemption applies when state procedures for immigration-status determination, reporting, or benefit restrictions interfere with federal statutory schemes and federal policy choices regarding enforcement priorities and eligibility rules.
- State requirements compelling educators, health-care providers, and social-service personnel to implement immigration-screening and exclusion policies can be preempted when they assign immigration-enforcement functions and classifications inconsistent with federal allocations of authority.

## Conclusion

The court held that the central components of Proposition 187—mandated immigration-status verification and reporting by state actors and broad benefit and service denials tied to those determinations—were preempted by federal immigration law and therefore unenforceable, and it entered permanent injunctive relief barring implementation of those provisions.


League of United Latin Am. Citizens v. Wilson, 908 F. Supp. 755 (C.D. Cal. 1995)