Senate Bill 54 (2017): California Versus the Law Enforcement Lobby


Before calls to abolish Immigration Customs and Enforcement (ICE) became a progressive rallying cry throughout the United States, the California Values Act of 2017 (SB 54) promised to freeze ICE out of California. The goal behind SB 54 was to restrict state and local law enforcement entanglement with ICE in the state with the most immigrants in the country. In fact, most deportations occurred because of this entanglement, relying on many facets of the criminal legal system, including jails, prisons, databases, and community patrols. Immigrants’ rights advocates, including from the ICE Out of California coalition, gained the political momentum they needed to pass the California Values Act after the 2016 election of President Donald Trump, a candidate who relied heavily on campaign promises of mass deportations to win.

This Comment examines both the legislative process of the California Values Act and its immediate efficacy as a statutory reform effort that sought to change the behavior of law enforcement officers. In particular, it documents how, despite public comments to the contrary, law enforcement agencies in California fought to remain involved in federal deportation efforts even after passage of the California Values Act. This Comment concludes that implementation of the law has produced mixed results. These findings present considerations for future efforts to address law enforcement agency collaboration with ICE, including the limitations of state level attempts more generally and whether it is possible to avoid SB 54’s mixed results.

About the Author

Law Clerk at the U.S. Court of Appeals for the Second Circuit; J.D., David J. Epstein Program in Public Interest Law and Policy and Critical Race Studies Program, UCLA School of Law, 2021; B.A., UC Irvine, 2015.