Melendres v. Arpaio

Plaintiffs had standing to pursue equitable relief against defendants, the Sheriff and Sheriff’s Office of Maricopa County, based on Fourth Amendment violations and the district court did not err when it granted plaintiffs’ partial injunctive relief, enjoining defendants from detaining individuals based solely on a knowledge or a reasonable belief that they are unlawfully present in the country.

Latino drivers and motor vehicle passengers and the organization Somos America (collectively “Plaintiffs”) brought an injunctive relief action against Sheriff Joseph Arpaio and the Maricopa County Sheriff’s Office (collectively “Defendants), alleging that Defendants “policy and custom” of racial profiling by the Sheriff’s Office during traffic stops violates the Fourth and Fifth Amendments of the Constitution, the Arizona Constitution, and the Civil Rights Act of 1964. The district court granted Plaintiffs partial injunctive relief enjoining Defendants from detaining persons based solely on knowledge or reasonable belief that they are in the country illegally. On appeal, Defendants asked the Ninth Circuit to consider a number of issues, including the district court’s decision that Plaintiffs have standing to sue for injunctive relief on their Fourth Amendment claim and whether the district court properly certified Plaintiffs as a class. The Ninth Circuit emphasized that it was only considering the district court’s grant of partial injunctive relief, as the district court had yet to enter a final judgment in this case, and, therefore, the Court’s review was limited to the preliminary injunctive relief order. The Court found that the district court did not err when it found that there was a policy of racial profiling during traffic stops in violation of the Fourth Amendment which was “sufficiently likely” to harm Plaintiffs in the future thereby giving Plaintiffs standing to pursue an injunction. The Ninth Circuit also declined to exercise its pendent jurisdiction to determine if the district court had properly certified plaintiffs as a class. AFFIRMED.