Saying his original decision was too broad, a federal judge this week ruled that an injunction prohibiting the state from enforcing part of a 2023 law aimed at cracking down on illegal immigration should be limited to plaintiffs who challenged the measure.
The lawsuit, filed by the Farmworker Association of Florida and individual plaintiffs, focuses on part of the law that threatens felony charges for people who transport into Florida an immigrant who 鈥渆ntered the United States in violation of law and has not been inspected by the federal government since his or her unlawful entry.鈥�
U.S. District Judge Roy Altman on May 22 sided with plaintiffs and granted a preliminary injunction blocking the part of the law, known as 鈥淪ection 10,鈥� from being enforced statewide. But the following day, the judge issued an order appearing to second-guess his decision and asked for 鈥渇urther briefing on the proper scope of the injunction.鈥�
Altman on Tuesday curtailed his original order and specified that the preliminary injunction applies only to the individual plaintiffs, who are Andrea Mendoza Hinojosa, Carmenza Aragon and Maria Medrano Rios; the farmworker association; and the association鈥檚 members as of the date of the order. The association has about 12,000 members statewide, according to court documents.
Although statewide injunctions can be suitable in some instances, the judge wrote that such a broad injunction 鈥渋sn鈥檛 appropriate in our case.鈥�
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Altman鈥檚 analysis relied, in part, on a concurring opinion by Justice Neil Gorsuch in a 2024 U.S. Supreme Court ruling in a case known as Labrador v. Poe. The Supreme Court decision scaled back a statewide injunction against an Idaho law that prohibited treatments such as puberty blockers and hormone therapy for transgender children and said the injunction should apply only to the two plaintiffs who challenged the law.
鈥淚t鈥檚 true that the alleged constitutional harm in our case is perhaps more expansive than the plaintiff-specific injuries at issue in Poe,鈥� Altman wrote.
But the judge added that, when he issued his original ruling for a statewide injunction, he relied on a decision by the 11th U.S. Circuit Court of Appeals saying that 鈥淐ongress has established an 鈥榦verwhelmingly dominant federal interest in the field鈥� of unlawfully transporting aliens.鈥�
Altman said he was guided in his revised ruling by Gorsuch鈥檚 more-recent opinion in the Idaho case. Gorsuch relied on 鈥渢he long-established maxim 鈥� a maxim we aren鈥檛 free to ignore 鈥� that 鈥榡udicial power exists only to redress or otherwise to protect against injury to the complaining party,鈥欌�� Altman wrote.
In a brief filed in June, lawyers for the plaintiffs urged Altman to keep his initial decision to block the law throughout Florida, saying there was 鈥渘o way to fully protect鈥� the association鈥檚 members from enforcement action while allowing enforcement against other people.
鈥淪tatewide relief is necessary to provide complete relief to the plaintiffs here, because there is no viable way to structure and enforce a more limited injunction that would fully protect the nearly 12,000 members of plaintiff Farmworker Association of Florida,鈥� the plaintiffs鈥� lawyers argued.
The lawyers acknowledged the ongoing debate about the propriety of statewide injunctions but said that 鈥渆very court to address the issue 鈥渉as agreed that they are appropriate鈥� when necessary.
But Altman disagreed this week.
鈥淲hile we鈥檙e sympathetic to these concerns, we don鈥檛 think they justify a broader injunction in our case,鈥� Tuesday鈥檚 order said.
The plaintiffs鈥� 鈥渇ears that they might suffer accidental harm absent a statewide injunction and that a more tailored injunction might be non-administrable are highly speculative and would require us to ignore the bedrock principle 鈥榯hat the remedy issued (cannot be) 鈥榤ore burdensome to the defendant than necessary鈥欌�� to provide relief to the plaintiffs, the judge said.
鈥淪o, while some of the plaintiffs have shown that they would suffer concrete harm if Section 10 were enforced against them 鈥� we disagree that expanding the scope of our injunction to include unidentified third-parties (many of whom may never have standing to sue and none of whom have elected to assert their claims here) would constitute a proper exercise of our jurisdiction,鈥� Altman, who was appointed to the bench by President Donald Trump, said.
In a June brief, attorneys for the state argued that 鈥渘o universal injunction is warranted here.鈥�
鈥淎t best, only the individual plaintiffs have standing and a cause of action. The injunction therefore should not apply beyond them, whether nationwide, statewide, or even district-wide,鈥� lawyers for the Florida attorney general鈥檚 office wrote.
But Altman鈥檚 ruling this week said the state鈥檚 arguments that the association should be cut out of the injunction were 鈥渦npersuasive鈥� and put guardrails around who would be covered.
鈥淭o ensure that FWAF (Farmworker Association of Florida) is afforded complete relief 鈥� but mindful that an injunction shouldn鈥檛 be indefinite or harmful to the plaintiffs 鈥� our injunction will apply only to persons who can verify that they were active FWAF members as of the date of this order,鈥� Altman said.
The 2023 law was part of a years-long effort by Gov. Ron DeSantis and the Republican-controlled Legislature to crack down on illegal immigration. Lawmakers met in a special session last month to pass a broad measure aimed at helping implement Trump鈥檚 deportation efforts.
