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DISCUSSION ON ADOPTING A RESOLUTION PROHIBITING THE USE OF CITY-OWNED OR CITY-CONTROLLED PROPERTY AND CITY RESOURCES FOR FEDERAL CIVIL IMMIGRATION ENFORCEMENT ACTIVITIES, EXCEPT AS REQUIRED BY LAW
recommended action
RECOMMENDATION
Receive information related to adopting a resolution prohibiting the use of City-owned or City-controlled property and City resources for federal civil immigration enforcement activities, except as required by law, and directing the City Manager to establish implementing administrative procedures, and provide staff direction on any changes or additional information the committee would like to receive and/or a recommendation for Council if appropriate.
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Summary
The proposed resolution (Attachment A) establishes a City policy governing the use of City property, facilities, personnel, equipment, technology, and other municipal resources in connection with federal civil immigration enforcement activities. The resolution is intended to preserve City resources for municipal purposes, promote public safety and community trust, and ensure consistent procedures for responding to requests involving City facilities, non-public areas, and City resources.
The resolution does not prevent federal agencies from carrying out responsibilities authorized by federal law, does not interfere with valid judicial warrants or court orders, and does not limit the City's cooperation in criminal investigations or emergency response activities. The resolution focuses on how City resources and facilities may be used and establishes administrative procedures for City employees when responding to requests related to federal civil immigration enforcement.
The proposed policy reflects approaches adopted by several California jurisdictions, including San José, Sacramento, Pasadena, and Los Angeles (Attachments B-E).
DISCUSSION
Background
Local governments throughout California have adopted policies clarifying the relationship between municipal operations and federal civil immigration enforcement. These policies generally seek to:
• Preserve access to City services and facilities.
• Promote trust between residents and local government.
• Ensure City resources are used consistent with local priorities.
• Establish clear procedures for employees responding to requests from federal immigration authorities.
The California Values Act establishes restrictions on the use of local law-enforcement resources for specified immigration-enforcement activities while preserving exceptions required by law.
The proposed resolution follows a property- and resource-management approach by regulating the City's use of its own facilities, personnel, equipment, and information systems. It does not attempt to regulate federal agencies directly.
Key Provisions
The resolution would:
• Prohibit the use of City-owned or City-controlled property as staging areas, processing locations, detention locations, or operations bases for federal civil immigration enforcement.
• Require requests for access to non-public City facilities to be reviewed through established supervisory and legal channels.
• Prohibit the use of City personnel, equipment, technology, and other municipal resources to facilitate federal civil immigration enforcement except as required by law.
• Establish procedures for employee notification, documentation, and records preservation.
• Direct the City Manager and City Attorney to develop implementing administrative procedures.
• Authorize signage and reasonable access-control measures at City facilities.
• Require review of future contracts and facility agreements for consistency with the resolution.
• Provide periodic reports to the City Council regarding implementation.
Comparable Policies
The proposed resolution incorporates elements derived from policies adopted by other California municipalities:
• San José Council Policy 7-15 prohibits City-controlled property from being used as staging areas, processing locations, or operations bases for civil immigration enforcement and includes signage and reporting provisions.
• Sacramento Resolution No. 2017-0158 prohibits the use of City resources to enforce federal civil immigration law and emphasizes public safety and community trust.
• Pasadena Resolution No. 9557 limits the use of City resources for federal immigration enforcement and protects sensitive information.
• Los Angeles Administrative Code Chapter 19 prohibits the use of City resources and property for specified immigration-enforcement activities and includes provisions relating to data protection and access to non-public facilities.
Legal Considerations
The Resolution is designed to regulate City property, resources, and employee conduct rather than federal activity. The Resolution expressly preserves:
• Compliance with federal and state law.
• Valid judicial warrants, subpoenas, summonses, and court orders.
• Emergency response activities.
• Cooperation in criminal investigations.
• Access to areas of City property lawfully open to the public.
• Existing contractual obligations.
Implementation procedures will be developed in consultation with the City Attorney to ensure consistency with applicable federal, state, and local law.
FINANCIAL SUMMARY
Adoption of the Resolution is not anticipated to have a significant direct fiscal impact. Implementation may require limited staff time associated with:
• Development of administrative procedures;
• Employee training;
• Preparation of periodic reports;
• Facility signage; and
• Review of contracts and facility agreements.
Any future costs associated with implementation will be addressed within existing departmental budgets or brought to the City Council for consideration if additional resources are required.
Attachment A - Proposed Council Resolution
Attachment B - City of San Jose Resolution RES2026-5
Attachment C - City of Pasadena Resolution 9557
Attachment D - City of Los Angeles Executive Order No. 17
Attachment E - City of Sacramento Resolution No. 2017-0158