This action might not be possible to undo. Are you sure you want to continue?
CANCEL
OK
Case 15-40238 S
TATE OF
T
EXAS
,
et al.
, U.S. Court of Appeals for the Fifth Circuit Plaintiffs-appellees, v. U
NITED
S
TATES OF
A
MERICA
,
et al.
, Defendants-appellants.
Motion of the Cato Institute and Prof. Jeremy Rabkin for Leave to File Brief as
Amici Curiae
in Support of Plaintiffs-Appellants
The Cato Institute and Prof. Jeremy Rabkin move for leave to file a brief as
amici curiae
in support of the plaintiff-appellant states. The parties consent to this motion. A copy of the proposed brief is attached.
A.
Interest of amici.
The Cato Institute is a nonpartisan public policy research foundation dedicated to advancing the principles of individ-ual liberty, free markets, and limited government. Cato’s Center for Constitutional Studies was established in 1989 to help restore the principles of constitutional government that are the foundation of liberty. Toward those ends, Cato pub-lishes books and studies, conducts conferences, and publish-es the annual
Cato Supreme Court Review
. Jeremy A. Rabkin is a professor of law at George Mason University School of Law. Prof. Rabkin’s fields of expertise
Case: 15-40238 Document: 00513036961 Page: 1 Date Filed: 05/08/2015
include administrative law, constitutional history, and stat-utory interpretation. As a matter of policy,
amici
support comprehensive immi-gration reform that provides relief to the aliens protected by DAPA (among many other purposes). It is not, however, for the President to make such changes alone, in conflict with the laws passed by Congress, and in ways that go beyond constitutionally-authorized executive power.
B.
Amici’s relevance to the case.
The
amici
have particular expertise in the structure and design of the federal Constitution and how that structure protects the rights and liberties of both America’s citizens and her guests. The offer that expertise to assist the Court with its determination as to the propriety of the executive action at issue and of the district court’s injunction.
C.
Conclusion and prayer.
The Cato Institute and Prof. Rabkin pray that the Court grant them leave to file their attached brief as friends of the court supporting the plaintiff-appellee states. They further pray for all other relief to which they may be entitled. Respectfully submitted, /s/ Leif A. Olson
2
Case: 15-40238 Document: 00513036961 Page: 2 Date Filed: 05/08/2015
Ilya Shapiro C
ATO
I
NSTITUTE
1000 Mass. Ave., N.W. Washington, D.C. 20001 (202) 842-0200 ishapiro@cato.org Josh Blackman (admission pending) P
ROFESSOR OF
L
AW
S
OUTH
T
EXAS
C
OLLEGE OF
L
AW
1303 San Jacinto Houston, Texas 77002 Leif A. Olson
Counsel of Record
T
HE
O
LSON
F
IRM
,
PLLC PMB 188 4830 Wilson Road, Suite 300 Humble, Texas 77396 (281) 849-8382 leif@olsonappeals.com Peter Margulies P
ROFESSOR OF
L
AW
R
OGER
W
ILLIAMS
U
NIV
.
S
CHOOL OF
L
AW
10 Metacom Ave. Bristol, Rhode Island
02809
Certificate of Conference
I certify that I conferred with counsel for the parties, who informed me that they don’t oppose this motion. /s/ Leif A. Olson
Certificate of Service
I certify that on May 8, 2015, this
Motion of the Cato In-stitute and Prof. Jeremy Rabkin for Leave to File Brief as Amici Curiae in Support of Plaintiffs-Appellants
was served on all counsel of record through the Court’s CM/ECF system. /s/ Leif A. Olson
3
Case: 15-40238 Document: 00513036961 Page: 3 Date Filed: 05/08/2015