Professional Documents
Culture Documents
GOP Parole Lawsuit
GOP Parole Lawsuit
STATE OF TEXAS,
STATE OF ALABAMA
STATE OF ALASKA
STATE OF ARKANSAS
STATE OF FLORIDA
STATE OF IDAHO
STATE OF IOWA
STATE OF KANSAS
COMMONWEALTH OF KENTUCKY
STATE OF LOUISIANA
STATE OF MISSISSIPPI
STATE OF MISSOURI
STATE OF MONTANA
STATE OF NEBRASKA
STATE OF OHIO
STATE OF SOUTH CAROLINA
STATE OF TENNESSEE
STATE OF UTAH
STATE OF WEST VIRGINIA
STATE OF WYOMING Case No. _________________
Plaintiffs,
v.
COMPLAINT
1. The Department of Homeland Security (DHS or Department),
under the false pretense of preventing aliens from unlawfully crossing the
border between the ports of entry, has effectively created a new visa program—
will permit up to 360,000 aliens annually from Cuba, Haiti, Nicaragua, and
Venezuela to be “paroled” into the United States for two years or longer and
been curtailed by Congress multiple times, and can be used “only on a case-by-
aliens in their home countries to obtain the benefit of being able to obtain
the law’s three limiting factors. It is not case-by-case, is not for urgent
thousands of aliens to enter the United States who otherwise have no basis for
doing so. This flouts, rather than follows, the clear limits imposed by Congress.
Procedure Act, substituting instead its unilateral judgment to bring into the
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authority to enter.
6. The Department does not have the authority to invite more than
a third of a million more illegal aliens into the United States annually as it has
7. This Court should enjoin, declare unlawful, and set aside the
Parties
I. Plaintiffs.
8. Plaintiff State of Texas is a sovereign State of the United States
of America.
States of America.
of America.
States of America.
of America.
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of America.
America.
of America.
States of America.
States of America.
States of America.
States of America.
America.
States of America.
States of America.
America.
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States of America.
States of America.
II. Defendants.
28. Defendant U.S. Department of Homeland Security is a cabinet-
level federal executive agency that oversees the Defendants, U.S. Citizenship
(CBP), and U.S. Immigration and Customs Enforcement (ICE), which are
constituent agencies of DHS. DHS and its constituent agencies are obligated
under the Constitution and laws of the United States. See 28 U.S.C. §§ 1331,
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34. This district is a proper venue because the State of Texas resides
Facts
instances where the government may use its authority to parole individuals
into the United States who otherwise would not be lawfully permitted to enter,
granted on a case-by-case basis, and even then, only for “urgent humanitarian
The text of section 212(d)(5) is clear that the parole authority was
intended to be used on a case-by-case basis to meet specific needs,
and not as a supplement to Congressionally-established
immigration policy. In recent years, however, parole has been used
increasingly to admit entire categories of aliens who do not qualify
for admission under any other category in immigration law, with
the intent that they will remain permanently in the United States.
This contravenes the intent of section 212(d)(5), but also
illustrates why further, specific limitations on the Attorney
General’s discretion are necessary.
H.R. Rep. No. 104-469, at 140 (1996) (emphasis added).
38. Congress has also emphasized that DHS “may not parole into the
determines that compelling reasons in the public interest with respect to that
particular alien require that the alien be paroled into the United States rather
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39. As the U.S. Court of Appeals for the Fifth Circuit stated less than
two years ago, “[q]uintessential modern uses of the parole power include, for
example, paroling aliens who do not qualify for an admission category but have
an urgent need for medical care in the United States and paroling aliens who
qualify for a visa but are waiting for it to become available.” Id. at 947. But the
power is not unlimited: “DHS cannot use that power to parole aliens en masse;
that was the whole point of the ‘case-by-case’ requirement that Congress added
40. The Supreme Court recently affirmed the limited nature of the
parole power, noting that it “is not unbounded: DHS may exercise its discretion
must be reasonable and reasonably explained.” Biden v. Texas, 142 S. Ct. 2528,
2543 (2022).
memorandum that created a new parole program for nationals of Cuba, Haiti,
announced the creation of the new parole program, which was modeled off
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recent programs the Defendants had created for nationals of Ukraine and
to Prepare for End of Title 42; Announces New Border Enforcement Measures
https://bit.ly/3VR83z2.
provide a lawful and streamlined way for qualifying nationals of Cuba, Haiti,
program “[w]e can provide humanitarian relief consistent with our values, cut
out vicious smuggling organizations, and enforce our laws.” Id. He added
“[i]ndividuals who are provided a safe, orderly, and lawful path to the United
States are less likely to risk their lives traversing thousands of miles in the
hands of ruthless smugglers, only to arrive at our southern border and face the
financial and other support” and certain background checks,“[aliens] can seek
46. The Defendants have further decreed that the program “will
allow up to 30,000 qualifying nationals per month from all four of these
countries to reside legally in the United States for up to two years and to
receive permission to work here, during that period.” Id. (emphasis added).
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48. The website lists the basic requirements for the program as they
were contained in its announcement the day prior, but added additional
details, including:
• The “supporter” agrees to provide the alien with financial support for
the duration of their parole in the United States and begins the process
• There is no cost to apply for the program for the alien or the “supporter.”
• Upon approval of the Form, the alien is authorized for travel to the
United States at the alien’s own expense, and upon arrival the alien will
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49. The Defendants did not publish advance notice of the program in
the Federal Register prior to posting details about the program on the
Department’s website.
separate Federal Register notices announcing the parole program that are
described below.
program, with one notice for each eligible nationality. See Implementation of a
Parole Process for Cubans, 88 Fed. Reg. 1266 (Jan. 9, 2023); Implementation
qualifications for it. But they do offer more analysis from the Department as
to why, in the Department’s view, the program comports with the limitations
on the Secretary’s parole power under 8 U.S.C. § 1182(d)(5). See, e.g., 88 Fed.
Reg. at 1260–63.
process. Instead, they asserted that their new program was exempt from
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involves a foreign affairs function of the United States,” and (3) “there is good
cause to find that the delay associated with implementing this process through
contrary to the public interest and impracticable.” See, e.g., 88 Fed. Reg. at
1264-65.
55. The Defendants did not explain or analyze how they would
remove from the United States aliens paroled through the program after the
56. The Defendants did not consult the Plaintiff States about the
potential effects of this program or the ability of the Plaintiff States to provide
57. The Defendants, if in fact they have devised a mechanism, did not
explain any such mechanism for the recovery of funds from “supporters” who
do not actually provide for the needs of aliens paroled under the program,
whether by the Department itself, any federal entity, or most pertinent to the
Plaintiff States, by any state.
education and healthcare, as well as many other social services. Federal law
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coverage for low-income children, families, seniors, and the disabled. Federal
and supportive services to victims and their children in Texas. Texas spends
more than a million dollars per year on the Texas Family Violence Program for
health coverage for children from birth through age 18. Texas spends tens of
63. Also, Texas spends tens of millions of dollars each year for
immigration.
64. Texas spends millions of dollars each year on public education
costs to educate illegal aliens, which puts a strain on its system for citizens and
65. If the Defendants allow these new aliens into the United States
in violation of federal law, then the harm will only grow over time.
67. Texas cannot recover from the federal government its increased
costs, which it would otherwise not incur if the federal government enforced
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the law. This affects Texas’s sovereign interests in its territory and its ability
to properly carry out such interests on behalf of the citizens of the State.
immigration.” Arizona v. U.S., 567 U.S. 387, 397 (2012). The State incurs
significant costs providing services to illegal aliens that it would otherwise not
incur if the federal government enforced the federal immigration law. Alabama
currently has tens of thousands of illegal aliens living in the State. Recent
reports estimate that approximately 55,000 to 73,000 illegal aliens are living
in the State; about 68% of them are uninsured; about 34% of them have
incomes below the poverty line; and these illegal aliens cost Alabama taxpayers
more than $324.9 million a year. See, e.g., MIGRATION POLICY INSTITUTE,
Unauthorized Immigrant Population Profiles, https://bit.ly/3kws01c (62,000
illegal aliens, 68% uninsured, 34% below poverty level) (last visited Jan. 23,
DHS Continues to Prepare for End of Title 42; Announces New Border
acknowledged that “the flow of migration directly impacts not only border
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power will inevitably increase the costs of Alabama’s healthcare system. See,
e.g., Plyler v. Doe, 457 U.S. 202, 223–30 (1982) (holding States constitutionally
of program participation).
71. Alaska will also be harmed by the parole program. Alaska has
approximately 5,000 to 11,000 illegal aliens living in the State. They cost the
State more than $72 million a year. If more illegal aliens enter Alaska, that
low-income children, families, seniors, and the disabled. Federal law requires
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Arkansas spends $7,349 on each child who attends its public schools, for a total
Ark. House of Reps., 2022 Education Adequacy Study (Jan 12, 2022),
aliens within the State. The presence of these illegal aliens in Florida—who
interest in its territory and the welfare of its citizens. It also costs the State of
76. Florida’s state prison system spends more than $100 million per
year incarcerating criminal aliens who commit crimes in Florida. Only a small
U.S.C. § 1231(i).
77. Florida spends more than $8,000 per student each year on public-
school education, which it provides regardless of immigration status.
79. Florida frequently pays the cost of emergency medical services for
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including parolees.
and healthcare, as well as many other social services. Federal law requires
Idaho to include illegal aliens in those programs. Like many Western states,
83. Idaho spends tens of millions of dollars each year to increase law-
environmental harm, and social disorder due to illegal immigration. See, e.g.,
aliens due to the federal government’s abuses of federal law. Those services
social services. Federal law requires Iowa to include illegal aliens in those
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illegal aliens receiving such services likewise increases, and so too the burden
Services Agency found that Iowa was home to an estimated 55,000 to 85,000
illegal immigrants. At that time, 16 years ago, the total cost of illegal
immigrants to the State General Fund was more than $100 million and
adjusting for inflation (without accounting for any increase in services or the
number of illegal immigrants) would bring that total to nearly $150 million
annually.
86. Iowa also spends tens of millions of dollars each year for increased
87. The total costs to Iowa of providing public education for illegal
alien children will rise in the future as the number of illegal alien children
88. Iowa has been identified as a hot spot for trafficking activity due
immigrants to and through the State. Proactively, in 2020, Iowa became one of
the first states in the country to pass legislation to require motel and hotel staff
89. If the Defendants are permitted to allow these new aliens into the
United States in violation of federal law, then the harm will only grow over
time.
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services, such as emergency medical care, public education, and other public
safety services.
91. Iowa cannot recover from the federal government its increased
costs, which it would otherwise not incur if the federal government enforced
the law. That affects Iowa’s sovereign interests in its territory and its ability
to carry out properly such interests on behalf of the citizens of the State.
further under the parole program because, under the program, the Defendants
will monthly admit into the interior many thousands of new aliens who will at
least temporarily reside there. This will be in addition to the many aliens who
illegally cross the border every day (whom the Defendants fail to apprehend).
See Bradford Betz, Mayorkas Testifies More Than 389,000 Migrant ‘Gotaways’
94. The program will result in increased crime and drug trafficking
enforcement. This is because at least some proportion of those aliens will come
whom will engage in illegal activity and whom law-enforcement officials will
1298, 1299–1300 (10th Cir. 1984) (recounting details of a traffic stop conducted
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bed of a pickup truck who admitted they were unlawfully present in the U.S.);
see also Tim Hrenchir, City settles police SUV crash lawsuit for $335K, TOPEKA
to pay $335,000 to settle a lawsuit over an April 2016 crash in which a vehicle
driven by an [illegal alien] was hit by a Topeka police SUV, which allegedly
went through a red light while responding to a call with its lights and siren
on.”); Glenn E. Rice, Man Who Heard Voices Charged With Murdering Tattoo
Artist, KAN. CITY STAR (May 22, 2018), https://bit.ly/3wpXqca, (discussing an
illegal alien who allegedly shot and killed another motorist while driving in
Kansas City, shot and wounded two men minutes apart in Clay County, and
Jackson County); THE ASSOCIATED PRESS, Murder & Abduction Suspect Living
in U.S. Illegally, CBS NEWS DFW (Nov. 24, 2016), https://cbsn.ws/3Wy24Qf (“A
mother and taking her baby was in the U.S. illegally when she was released
from [Sedgwick County (KS) Jail] this summer before immigration officials had
and Venezuela to obtain advance authorization to enter the United States, the
parole program will force Kansas to expend its limited resources on education,
individuals who are not U.S. citizens. See Plyler v. Doe, 457 U.S. 202, 223–30
free public education); KAN. STATE DEP’T OF EDUC., EXPENDITURES PER PUPIL:
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medical assistance programs, non-U.S. citizens must hold (1) legal residency
in the U.S. for 5 years or more or (2) hold a certain immigration status.”); KAN.
DEP’T OF HEALTH & ENV’T, DIV. OF HEALTH CARE FIN., MKEESM MANUAL
purpose of this chart is to provide policy guidance for eligibility staff when
addressing requests for coverage when the individual attests to being a non-
“[illegal aliens] have been found to use hospital and emergency services at over
twice the rate of the overall U.S. population,” and observing that there is a
living in the State, about 64% of whom are uninsured and about 25% of whom
have incomes below the poverty line. See MIGRATION POLICY INSTITUTE, Profile
aliens, 81% from “Mexico and Central America,” 64% uninsured, 11% below
50% of the poverty level); PEW RESEARCH CTR., U.S. Unauthorized Immigrant
(75,000 illegal aliens). These illegal aliens cost Kansas taxpayers more than
$377 million per year. See FED’N FOR AM. IMMIGRATION REFORM, The Fiscal
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Kentucky will be required to stretch its scarce resources even further under
released into the United States, including Kentucky, which increases the
immigration by allowing illegal aliens who have already illegally entered the
United States to act as “supporters” and encourage aliens who have not yet left
their countries to do so. As a result, the Defendants’ unlawful actions will lead
in the Commonwealth; about 60% of them are uninsured; about 37% of them
have incomes below the poverty level; and they cost Kentucky taxpayers more
than $261 million per year. If more illegal aliens enter the Commonwealth,
aliens residing in Kentucky that are under the age of 16. Under Kentucky law,
attend public school until age 16, with exceptions for students who attend
private, parochial, or home school options. Ky. Rev. Stat. § 159.010. The
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will increase educational costs, including, but not limited to, requiring
Louisiana will be required to stretch its resources even further under the
parole program, because the parole program involves the unlawful release of
hundreds of thousands of illegal aliens into the United States. The parole
aliens living in the State who are not lawfully in the United States. More than
70% of them do not have health insurance, about 34% of them have incomes
below the poverty level, and they cost Louisiana taxpayers more than $362
73% uninsured, 34% poverty level); PEW RESEARCH CENTER U.S. Unauthorized
illegal aliens, $362 million annual cost). More aliens entering the State will
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directly and concretely affected by changes to DHS rules and policies that have
budgets, as well as its other important health, safety, and pecuniary interests
the Louisiana Department of Justice at 1-2. DHS has also recognized that
crime, consumption of public benefits and services, strain upon the healthcare
competition with the State of Louisiana's current residents for, among other
otherwise not incur if the federal government enforced the law, from the
the State.
be required to stretch its scarce resources even further under the program
because it will cause an influx of illegal aliens who otherwise have no basis for
entering the country. The program will further incentivize and exacerbate
illegal immigration, and thus will force Mississippi to expend limited resources
government services.
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living in the State; about 75% of them are uninsured; about 49% of them have
incomes below the poverty level; and they cost Mississippi taxpayers more than
$117 million per year. If more illegal aliens enter the State, that will increase
significant numbers of illegal aliens who enter the United States end up
residing in Missouri. See Texas v. Biden, 554 F. Supp. 3d 818, 838 (N.D. Tex.
2021), aff’d, 20 F.4th 928 (5th Cir. 2021), rev’d on other grounds, 142 S. Ct.
of the unlawful presence of illegal aliens in the State in the form of education,
109. Illegal aliens and their children receive education benefits from
Missouri at Missouri’s expense. See Plyler v. Doe, 457 U.S. 202, 205, 230 (1982)
children who are citizens of the United States or legally admitted aliens”).
110. As the District Court for the Northern District of Texas has found,
the costs to “Missouri … of providing public education for illegal alien children
will rise … as the number of illegal alien children present in the State
111. “Some aliens who … are being released or paroled into the United
Id. “The total costs to [Missouri] will increase as the number of aliens within
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trafficking crimes within the United States, due to its situation at the
migrants from Central America who have crossed the border illegally.”). Illegal
aliens are disproportionately the victims of these crimes. Some illegal aliens
enforcement costs and in providing resources for victims. See id. (finding that
Patients Can’t Get Treatment for Substance Abuse, ST. LOUIS PUBLIC RADIO
(Apr. 5, 2022), https://bit.ly/3QVv9nr. “St. Louis ranks among the deadliest
cities in the country for overdose deaths among African Americans, and … the
Black community seems caught between organized crime’s fentanyl push and
ineffective efforts to stop it.” Id. Drug smugglers unlawfully entering the
United States through the southern border are critical suppliers for
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illegal aliens impose major healthcare and law-enforcement costs on the State.
An increased influx of illegal aliens will exacerbate these problems. See Texas,
554 F. Supp. 3d at 839 (finding that “[s]ome aliens who … are being released
labor market and reduce job opportunities for U.S. citizens and aliens lawfully
present in Missouri, as illegal aliens frequently compete for jobs at lower wages
than workers who are lawfully present. Missouri has a large agricultural
market and inflict irreparable injury on both the State and its citizens.
117. Montana bears the costs of illegal aliens, including their U.S.-
118. Because Montana has no state sales tax, many illegal aliens pay
virtually no state taxes. Therefore, the costs of all the public services they
consume are borne by lawfully present taxpayers.
119. Ohio will also be irreparably harmed by the parole program. Ohio
within the State. The illegal parole program will increase the number of illegal
aliens in Ohio. While illegal border crossings most severely affect border
States, the parole program requires aliens to “provide for their own commercial
travel” to the United States, and therefore will affect States beyond the border.
illegal aliens, particularly given the requirement that the alien associate with
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emergency medical services and schooling. Ohio schools spend more than
immigration status. Ohio is unable to recover these costs from the federal
government and would not incur these costs but for the federal government’s
services to illegal aliens within the State. For example, South Carolina spends
123. The parole program will necessarily lead to a new inflow of illegal
qualifying individuals per month from all four countries will be admitted to the
United States under the program. The program could thus allow for the entry
of up to 360,000 new illegal aliens to enter the United States per year. Because
the program will significantly increase the total number of illegal aliens in the
country, the program will harm South Carolina by causing it to expend even
Institute analysis of U.S. Census Bureau data from the pooled 2015–2019
services and healthcare, as well as many other social services. As the number
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127. Utah is also harmed. The parole program will create increased
crime and drug trafficking in Utah’s communities, requiring additional
immigration, the parole program will force Utah to expend limited resources
the State; about 61% of them are uninsured; about 23% of them have incomes
below the poverty line; and they cost Utah taxpayers more than $521 million
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policy regarding immigration. It incurs costs related to its nearly 4,000 illegal
West Virginia spends more than $12,000 per year per public-school student,
and it provides public education and related benefits (such as free or reduced-
aliens enter West Virginia, that will increase West Virginia's education,
Wyoming will be required to stretch its scarce resources even further under
the new program because it will cause an influx of illegal aliens to be released
into the United States (including to Wyoming) which increases the burden on
the State, and they cost Wyoming taxpayers more than $26.1 million a year.
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132. If more illegal aliens enter the State, that will increase the costs
court shall decide all relevant questions of law, interpret the constitution and
action. Then, it shall hold unlawful and set aside agency action, findings, and
required by law.
134. The Defendants’ parole program should be held unlawful and set
aside because:
rulemaking.
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e. The Defendants arbitrarily did not consider and account for the
here.
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was issued in violation of the APA and vacate it, set it aside, or in
implementing it;
• Award the Plaintiff States their attorneys’ fees and costs of court;
and
• Award the Plaintiff States all other relief to which they may be
entitled.
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GENE P. HAMILTON*
America First Legal Foundation
300 Independence Avenue SE
Washington, DC 20003
Tel: (202) 964-3721
[email protected]
Counsel for the State of Texas
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STEVE MARSHALL
Alabama Attorney General
EDMUND G. LACOUR JR.
Solicitor General
Office of the Attorney General
State of Alabama
501 Washington Avenue
P.O. Box 300152
Montgomery, Alabama 36130-0152
Tel: (334) 242-7300
Fax: (334) 353-8400
[email protected]
TREG R. TAYLOR
Attorney General of Alaska
CORI M. MILLS
Deputy Attorney General of Alaska
CHRISTOPHER A. ROBISON
Alaska Bar No. 2111126
Texas Bar No. 24035720
Assistant Attorney General
Alaska Department of Law
1031 W. 4th Avenue, Suite 200
Anchorage, Alaska 99501-1994
[email protected]
TIM GRIFFIN
Arkansas Attorney General
NICHOLAS J. BRONNI
Arkansas Solicitor General
HANNAH L. TEMPLIN
Assistant Solicitor General
Office of the Arkansas
Attorney General
323 Center Street, Suite 200
Little Rock, Arkansas 72201
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ASHLEY MOODY
Attorney General of Florida
JAMES H. PERCIVAL (FBN 1016188)
Deputy Attorney General of Legal
Policy
Office of the Attorney General
The Capitol, Pl-01
Tallahassee, Florida 32399-1050
Tel: (850) 414-3300
Fax: (850) 410-2672 (fax)
[email protected]
RAÚL R. LABRADOR
Attorney General of Idaho
DAVID M.S. DEWHIRST, ISB No. 12141
Chief Deputy Attorney General
Office of the Attorney General
700 W. Jefferson Street, Ste. 210
P.O. Box 83720
Boise, Idaho 83720-0010
Tel: (208) 334-2400
Fax: (208) 854-8071
[email protected]
BRENNA BIRD
Attorney General of Iowa
ERIC H. WESSAN
Solicitor General
1305 E. Walnut Street
Des Moines, Iowa 50319
Tel: (515) 281-5164
Fax: (515) 281-4209
[email protected]
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KRIS KOBACH
Attorney General of Kansas
JESSE A. BURRIS, Kan. Sup. Ct. #26856
Assistant Attorney General
Office of Kansas Attorney General Kris
Kobach
120 SW 10th Avenue, 2nd Floor
Topeka, Kansas 66612-1597
Tel: (785) 368-8197
Fax: (785) 296-3131
[email protected]
DANIEL CAMERON
Attorney General of Kentucky
MARC MANLEY
Associate Attorney General
Kentucky Office of the
Attorney General
700 Capital Avenue, Suite 118
Frankfort, Kentucky
Tel: (502) 696-5478
JEFF LANDRY
Attorney General of Louisiana
ELIZABETH B. MURRILL (La #20685)
Solicitor General
JOSEPH SCOTT ST. JOHN (La #36682)
Deputy Solicitor General
Louisiana Department of Justice
1885 N. Third Street
Baton Rouge, Louisiana 70804
Tel: (225) 326-6766
[email protected]
[email protected]
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LYNN FITCH
Attorney General of Mississippi
JUSTIN L. MATHENY
Deputy Solicitor General
Office of the Mississippi
Attorney General
P.O. Box 220
Jackson, MS 39205-0220
Tel: (601) 359-3680
[email protected]
ANDREW BAILEY
Attorney General of Missouri
JOSHUA M. DIVINE, Mo. Bar #69875
Solicitor General
CHARLES F. CAPPS, Mo. Bar #72734
Deputy Solicitor General
Missouri Attorney General’s Office
Post Office Box 899
Jefferson City, Missouri 65102
Tel: (573) 751-8870
Fax: (573) 751-0774
[email protected]
AUSTIN KNUDSEN
Attorney General of Montana
CHRISTIAN B. CORRIGAN
Solicitor General
PETER M. TORSTENSEN, JR.
Assistant Solicitor General
Office of the Attorney General
215 N Sanders
Helena, Montana 59601
Tel: (406) 444-2026
[email protected]
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Case 6:23-cv-00007 Document 1 Filed on 01/24/23 in TXSD Page 38 of 39
MICHAEL T. HILGERS
Attorney General of Nebraska
ERIC J. HAMILTON
Deputy Solicitor General
Office of the Nebraska Attorney General
2115 State Capitol
Lincoln, Nebraska 68509
Tel: (402) 471-2682
[email protected]
DAVE YOST
Ohio Attorney General
SYLVIA MAY MAILMAN
Ohio Deputy Solicitor General
30 E. Broad St., 17th Floor
Columbus, OH 43215
Tel: (614) 466-8980
[email protected]
ALAN WILSON
Attorney General of South Carolina
THOMAS T. HYDRICK
Assistant Deputy Solicitor General
Post Office Box 11549
Columbia, SC 29211
Tel: (803) 734-4127
[email protected]
JONATHAN SKRMETTI
Tennessee Attorney General and Reporter
CLARK L. HILDABRAND
Assistant Solicitor General
P.O. Box 20207
Nashville, TN 37202
Tel: (615) 253-5642
[email protected]
38
Case 6:23-cv-00007 Document 1 Filed on 01/24/23 in TXSD Page 39 of 39
SEAN D. REYES
Utah Attorney General
MELISSA HOLYOAK
Utah Solicitor General
350 N. State Street, Suite 230
P.O. Box 142320
Salt Lake City, UT 84114-2320
Tel: (801) 538-9600
[email protected]
PATRICK MORRISEY
Attorney General of West Virginia
LINDSAY SEE
Solicitor General
MICHAEL R. WILLIAMS
Senior Deputy Solicitor General
Office of the West Virginia Attorney General
State Capitol, Bldg 1, Room E-26
Charleston, WV 25305
Tel: (681) 313-4550
[email protected]
[email protected]
BRIDGET HILL
Wyoming Attorney General
RYAN SCHELHAAS
Chief Deputy Attorney General
Wyoming Attorney General’s Office
109 State Capitol
Cheyenne, WY 82002
Tel: (307) 777-5786
[email protected]
39