A federal judge in Los Angeles — Central District Judge Maame Ewusi-Mensah Frimpong, a Biden appointee — issued a temporary restraining order yesterday preventing the government from using certain characteristics (like race, ethnicity, language, or location) as the sole basis for reasonable suspicion to stop individuals in immigration enforcement actions. The order also includes requirements for record-keeping, developing official guidance on reasonable suspicion, and implementing mandatory training for agents.
The case is captioned Perdomo v. Noem. Judge Frimpong’s 52-page “order granting ex parte applications for temporary restraining order and order to show cause” is posted online at the link.
That’s some order. I may be missing something — trust but verify — but here are a few observations.
• I take it that Judge Frimpong did not bother to await a response from any of the numerous defendants in the case. That’s what “ex parte” means. If she had awaited their response, she would have issued a preliminary injunction. As it is, the order requires defendants to “show cause” why she shouldn’t issue a preliminary injunction.
• The judge’s order is suggestive of the limits on the recent Supreme Court ruling in Trump v. Casa, Inc.. The ruling purported to restrain the federal courts from promulgating “universal” injunctions in most cases.
• To circumvent the Casa holding, it is apparently sufficient for an outfit with organizational standing, for example, to invoke the necessity of an injunction to provide “complete relief.” In this case, the plaintiff organizations include the Los Angeles Worker Center Network, the United Farm Workers, and Coalition for Humane Immigrant Rights. The necessity of “complete relief” provides an exception to the limits imposed by the Supreme Court, but it sounds a tad formulaic in Judge Frimpong’s order.
• At page 15, Judge Frimpong states in bold: “[T]his Order is not a final decision on the merits of any claim, nor is it a decision on the factual merits of the factual assertions either party made in support of any claim.” Well, thanks. Defendants haven’t even been heard yet.
• I count ten plaintiffs. The reference to “either party” mystifies me. Does she mean any party? You be the judge.
• At page 15, Judge Frimpong purports to be determining whether “plaintiffs have met their burden for a preliminary injunction.” However, defendants appear not to have responded to plaintiffs’ motion or even to have filed an answer in the case. The order at pages 49-52 grants a temporary restraining order rather than a preliminary injunction. As I say, defendants apparently have yet to be heard.
• The Supreme Court has more work to do.
• U.S. Attorney for the Central District of California Bill Essayli issued the statement below in response to Judge Frimpong’s ruling.
Statement in response to today’s ruling in Perdomo et al. v. Noem et al.
We strongly disagree with the allegations in the lawsuit and maintain that our agents have never detained individuals without proper legal justification. Our federal agents will continue to enforce the law…
— U.S. Attorney Bill Essayli (@USAttyEssayli) July 12, 2025
