Labor & Employment Law Daily Wrap Up, IMMIGRATION—C.D. Cal.: Federal judge temporarily halts Trump Administration’s ‘roving patrols’ in Los Angeles ICE raids, (Jul 15, 2025)

By Marjorie Johnson, J.D.

The court issued a TRO barring federal law agents from indiscriminately rounding up individuals without reasonable cause and then denying them access to legal counsel, including advocacy groups that sought entry.

A federal district court in California issued a temporary restraining order (TRO) halting two controversial practices being carried out by the Trump Administration during immigration raids in the Los Angeles area since early June: (1) sending “roving patrols” of federal law agents who indiscriminately stop and detain numerous individuals without reasonable suspicion allegedly in violation of the Fourth Amendment; and (2) bringing those individuals to an unsanitary detention facility and denying them access to legal counsel allegedly in violation of the Fifth Amendment. In this class action lawsuit brought by several detainees, immigration rights groups, and others, the court held that the plaintiffs were likely to succeed in showing that the agents stopped and detained individuals without reasonable cause based solely on their race, their Spanish-speaking status, their presence at a particular location, and/or the type of work they performed, and then denied them from accessing legal representation (Perdomo v. Noem, No. 2:25-cv-05605-MEMF-SP (C.D. Cal. July 11, 2025)).

Sweeping LA raids. In early June 2025, federal law enforcement arrived in Los Angeles to participate in what federal officials have described as “the largest Mass Deportation Operation... in History.” Individuals who were stopped described military-style raids by heavily armed federal agents who were masked, did not identify themselves, shouted commands, and physically restrained them. The agents then allegedly took them to an overcrowded and windowless detention facility that lacked basic sanitation, deprived them of food or water, and barred legal advocacy groups and family members from seeing them.

Class action. Detainees and immigration advocacy groups were among the plaintiffs who brought this class action lawsuit alleging the administration’s actions violated the Fourth and Fifth Amendments. While federal officials agreed that the actions as alleged would be unconstitutional, they argued that the violations were not occurring. The judge was unconvinced.

TRO as to raids. Citing a “mountain of evidence,” the court granted plaintiffs’ bid for a TRO halting the administration from detaining individuals without the legally required reasonable suspicion and from solely relying on these four enumerated factors: (1) apparent race or ethnicity, (2) speaking Spanish or speaking English with an accent; (3) presence at a particular location; or (4) the type of work one does. After rejecting the government’s jurisdictional argument and contention that the TRO could not be issued without class certification, the court found that the plaintiffs were likely to succeed in showing that seizures during the immigration raids occurred based solely upon those enumerated factors, either alone or in combination, and as such violated the Fourth Amendment.

Racial profiling. In addition to other evidence of racial profiling, the court pointed to the individual plaintiffs’ testimony that while they were waiting to be picked up for their work on the morning of June 18, they were suddenly approached by four unmarked cars and, although nothing suggested that they were in the country without proper documentation or had already or were about to commit a crime, the masked and armed men proceeded to seize them and take them to the detention facility.. While the administration argued that the seizures were based upon a particularized assessment of reasonable suspicion based upon articulable facts, the evidence of the “roving patrols” suggested otherwise.

Sole reliance. The court also found that the federal agents’ sole reliance on the enumerated factors—race, being Spanish-speaking, and presence at a particular location or the type of work—could not give rise to reasonable suspicion. For instance, the government did not explain why being at a bus stop in Pasadena raised suspicion that the individuals may be undocumented immigrants. Moreover, an agent’s statement that past experiences had demonstrated that illegal aliens sought work at “certain types of businesses, including car washes,” did not demonstrate a particularized assessment was made.

The court also found that the requested TRO was tailored to the specific harm alleged since the plaintiffs sought only to bar reliance solely on the four enumerated factors and did not claim that the agents could not consider them in addition to other factors. Moreover, not only would the deprivation of the plaintiffs’ constitutional rights constitute an irreparable injury, but under the circumstances, the “the broader public may also be in fear of having their constitutional rights violated by seizures without reasonable suspicion.” Finally, the court rejected the administration’s contention that granting the TRO would prejudice the government, explaining that “requiring law enforcement to comply with the Constitution does not prevent law enforcement from enforcing the law.”

Denial of access to counsel. The court also held that the legal advocacy groups demonstrated standing, injury-in-fact, and causation with regard to plaintiffs’ Fifth Amendment claims alleging the federal officials impeded their ability to provide legal representation to immigrants and refugees, which was the “core of their founding missions.” They claimed their attorneys were denied access to the detainees at the LA facility and were even sprayed with “an unknown chemical agent” that caused “everyone to cough and inflicted a burning sensation in the eyes, nose, and throat.” In response, the administration only attempted to minimize the impact of these facts and characterized them as limited to a short period of time justified by nearby civil unrest.

Reasonable fear of detention. “The government cannot impose restrictions on access to counsel that undermine the immigrant’s opportunity to obtain one,” explained the court, and the detainees had a reasonable fear of being subjected not only to the alleged stop-and-arrest practices, but also the subsequent detention at the LA facility. The TRO was also tailored to the specific harms as it only provided the detainees with the same legal visitation and confidential telephone calls that the federal government provided at other locations. And considering the fear of being separated from their families as a result of the administration’s enforcement actions, the nonprofit’s members were at an imminent risk of irreparable harm.

Well-established due process rights. Finally, the balance of equities tipped in plaintiffs’ favor since the TRO merely required that the administration comply with the “well-established due process right of access to counsel” by providing individuals detained at the LA facility with the same access that the government already afforded those held at other immigration detention facilities under the government’s National Detention Standards The public interest also heavily favored granting the TRO since “[v]iolation of the Fifth Amendment raises public interest concerns, not only for those who are currently detained, but also for those who may be arrested and/or detained in the future.” Moreover, the administration failed to show its interest in enforcing immigration laws could not be met without undermining immigrants’ Fifth Amendment rights.

The case is No. 2:25-cv-05605.

Judge: Frimpong

Attorneys: Stacy Eva Tolchin (Law Offices of Stacy Tolchin) for Pedro Vasquez Perdomo. Pauline Helen Alarcon, Office of U.S. Attorney, for Kristi Noem.

Cases: Immigration ImmigrationNews IndividualRights Discrimination RaceDiscrimination NationalOrigin Procedure RemediesDamages ClassActions CaliforniaNews