Preliminarily and permanently enjoin Defendants from engaging in the unlawful
actions described in this Complaint, specifically prohibiting Defendants, their
officers, agents, assigns, and all persons acting in concert with them from:
a. Arresting or threatening to arrest any person who is not subject to a lawful
immigration arrest unless there is probable cause to believe the individual has
committed a crime;
b. Threatening or using physical force, including brandishing weapons, against
any person who is not subject to a lawful immigration arrest where such threat
or force is not reasonably necessary to stop an immediate and serious threat of
physical harm to a law enforcement officer or another person and there is not
reasonable suspicion or probable cause that the person subject to force or
threatened with force has committed a crime;
c. Dispersing individuals engaged in First Amendment-protected activity with
physical force. Defendants may ask an individual engaged in First Amendmentprotected activity to change location to avoid disrupting law enforcement, as
long as the instructions are clear and the individual has time to comply and
sufficient opportunity to observe and exercise his or her First Amendment
rights;
d. Pointing firearms at individuals who are not posing an immediate threat of death
or serious bodily injury to another person;
e. Using hands-on physical force such as pulling or shoving to the ground,
