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November 27, 1996
In The United States District Court
For The Northern District of California
Coalition for Economic Equity, et al..

Vs.

Pete Wilson, et al, Defendant


Order Temporary Restraining Order

Introduction

This maker came before the Court on Monday , November 25, 1996 on plaintiffs' Application for Temporary Restraining order ("TRO") In particular plaintiffs [1] seek an order that would temporarily enjoin defendants Governor Pete Wilson and Attorney General Dan Lungren [2] from enforcing or implementing Proposition 209 after hearing extensive argument from the parties the Court took plaintiffs' Application for TRO under submission.

This Court Is mindful that any challenge to a duly enacted law should be met with caution and restraint. It is not for this or any other court to lightly upset the expectations of the voters. At the same time federal courts have no role more important than to uphold the federal Constitution and ensure that the laws of our states do not violate basic constitutional rights that form the very foundation of our system of democracy That role is of course the same whether the law under consideration was enacted by legislators in the state capital or by voters at the ballot box Indeed in a case of this nature the issue is not whether this Court should reject or respect the "will of the people.. "Rather the issue is whether the challenged enactment complies with the laws of our Constitution and Bill of Rights.

This Court is also aware that whenever issues affecting race and gender enter into the electoral process some degree of controversy is inevitable. It bears emphasizing however that this case does not call upon this Court to adjudicate whether affirmative action is right or wrong or whether it is no longer an appropriate policy for addressing the continuing effects of past and present discrimination against racial minorities and women. Such questions while they are most certainly of vital public policy interest lie beyond the purview of this Court. Rather the substantive issues raised by this action are considerably more narrow albeit no less important : whether the particular method chosen by Proposition 2O9 to curtail affirmative action is unlawful bemuse it violates the United States Constitution.

The focus of the instant motion is narrower still. It is only to determine whether it is appropriate to temporarily maintain the pre election status quo for the next ten to twenty days in order to afford the Court more time to fully consider the merits of plaintiff's' challenge on a motion for a preliminary injunction. It is with these considerations ions in mind that the Court turns to plaintiffs' Application

Legal Standard

A party seeking a TRO must satisfy the same test required for the issuance of a preliminary injunction. See Lockheed Miss e 8 Space Co. v. Hughes Aircraft Co., 887 F. Supp. 132O, 1323 ~N D. Cal. 1995). According to Ninth Circuit precedent, to obtain a preliminary injunction, the moving party must demonstrate e either (1 ) a combination of probable success on the merits and the possibility of irreparable injury or (2) that serious questions are raised and the balance of hardships in favor of the movant Associated Gen. Contractors of Cal. v. Coalition for Econ. Equity. 950 F. 2d 1401, 1410 (9th Cir. 1991), cert. denied. 503 U.S. 985 (1992). These formulations are not different tests but rather two points on a sliding scale in which the degree of irreparable harm increases as the probability of success on the merits decreases. Id. In considering a request for a TRO a court must remain n mindful that such relief is aimed primarily at preserving the status quo pending a full hearing I on a preliminary injunction. Cf.. Los Angeles Mem. Coliseum Comm'n v. National Football League, 634 F.2d 1197, 1200 (9th Cir. 198O) ("fundamental principle" governing preliminary injunctive relief is the need to maintain the status quo prior to determination on the merits). In addition, under either formulation of the test, a court in balancing the harms must take into account the public interests that are implicated by the injunctive relief sought. Caribbean Marine SON Go v Baldrige see. 844 F.2d 668. 674 (9th Cir. 198B).

Discussion

As noted above, plaintiffs seek to temporarily enjoin Governor Pete Wilson and Attorney General Daniel Lungren from enforcing or implementing Proposition 209, now embodied in the California Constitution, Article I, Section 31 13.41

Likelihood of Success on the Merits

"The Equal Protection Clause of the 14th Amendment guarantees racial minorities the right to full participation in the political life of the community.".. Washington v. Seattle Sch. No 1, 458 U.S. 457, 467 (1982). This guarantee not only prohibits the outright exclusion of women and minorities from the political process, but a so prohibits more subtle distortions of the poling process that place special burdens on the ability of women and minorities to achieve beneficial legislation. Id, In the words of the Supreme Court, the State may no more disadvantage any particular group by ma king it more difficult to enact legislation in its behalf than it may dilute any person's vote.. Id. at 476 (quoting Hunter v. Erickson, 393 U.S. 385. 393 (1969)).

Plaintiffs argue that Proposition 209, despite its facial neutrality violates the Equal Protection Clause because it restructures the political process to disadvantage those seeking to enact affirmative act on programs designed to remedy past or present discrimination against women and minorities. Relying on the Supreme Court opinions in Seattle and Hunter, plaintiffs emphasize that prior to the passage of Proposition 209, supporters of affirmative action were able to petition their state and local officials for race and gender-conscious programs aimed at remedying discrimination Since the passage of Proposition on 209, those seeking such programs must resort to a statewide initiative to amend the California Constitution At the same time, individuals seeking preferences based on any other ground, such as age, disability or veteran status, continue to have access to the political process at all levels. In other words, according to plaintiffs Proposition 209 requires that advocate; of affirmative action, and no one else, must affirmative a higher political hurdle.

Defendants contend that Proposition 209, by its terms. prohibits classifications based on race and gender and therefore cannot be read to create such classifications The Supreme Court, however, has made it dear that courts must look beyond the plain language of an enactment. The relevant question is whether, in reality. the burden imposed by a law necessarily falls on minorities and women. W. at 468 As Seattle demonstrates, an otherwise facially neutral law, it burdens the interests of the minority and restructures the political process, may operate in reality as a radar or gender classification The evidence presently before the Court strongly suggests that, as a result of the passage of Proposition 209, "the community's political mechanisms [have been modified to place effective decision-making authority over a racial issue at a different level of government." Seattle, 458 U.S. at 474. In light n of the foregoing, the Court is satisfied that plaintiffs have demonstrated a probability that this case is controlled by the analysis articulated by the Supreme Court in Washington v. Seattle School District No. I, 458 U.S. 457 (1982), and that plaintiffs have demonstrated a probability of success on their equal protection claim. [5]

Possibility of Irreparable Injury

Having demonstrated a strong probability of success on the merits, plaintiffs must a so show a possibility of irreparable injury. Where the deprivation of a constitutional right is involved. courts generally hold that no further showing of irreparable injury is necessary. See Associated En. Contractors, 950 F.2d at 1412, 11A Wright & Miller, FEDERAL PRACTICE AND PROCEDURES § 2948 1. Plaintiffs must, nonetheless, demonstrate that constitutional harm is imminent during the brief period prior to this Court's taking up the motion for preliminary injunction.

The Court is satisfied that plaintiffs face an immediate possibility of irreparable harm. The evidence assembled by plaintiffs indicates that the Governor and Attorney General have acted with considerable dispatch in implementing Proposition 209. These prompt implementation measures, viewed in conjunction with the refuse by the Governor and Attorney General to agree to a moratorium on enforcement actions against municipalities, agencies, and other state entities,[6] adequately support plaintiff's allegation that the class faces the possibility of in mediate injury. Plaintiffs concerns, when viewed in light of the entire record, cannot be dismissed as merely speculative The record reflects, for example, that the Governor, on the day after the amendments passage, attempted to invoke Proposition 209 in a state court proceeding aimed at striking down existing state affirmative action programs

Finally, this Court also finds that the balance of harms tips decidedly in favor of the moving party. The constitution for a few days of affirmative action programs already in place does not impose any undue hardship on the State of California. on the other hand, the public interest in remedying discrimination, which underlies existing governmental affirmative action programs, weighs in favor of granting a TRO.

Conclusion

The TRO is a preliminary action directed at maintaining the status quo until a court has an opportunity to more fully explore the merits of a case. The e Court today finds that plaintiffs have demonstrated that such a TRO Is appropriate and that the pre- electron status quo should be preserved until this Court can consider the panics arguments on plaintiffs motion for preliminary injunction.

Accordingly and good cause appearing defendants Governor Pete Wilson and Attorney General Daniel Lungren are HEREBY ORDERED TO SHOW CAUSE on Monday December 16, 1996 at 10:0O a.m. in Courtroom 5, 450 Golden Gate Avenue, San Francisco, California, why you, your of ricers, agents, servants, employees and attorneys and those in active concert or participation with you or them should not be restrained and enjoined, pending trial on this action, from implementing or enforcing Proposition 209 insofar as said amendment to the Constitution of the State of California purports to prohibit or affect affirmative action programs in public employment, pubic education or public contracting.[8]

Pending hearing on the above order to Show Cause. you, your officers, agents, servants, employees and attorneys and those in active concert or participation with you or them are HEREBY RESTRAINED AND ENJOINED except as otherwise stated below, from implementing or enforcing Proposition 209 insofar as said amendment to the Constitution of the State of California purports to prohibit or affect affirmative action pro grams in public employment public education on or public contracting.

At the hearing, counsel for defendants requested that any TRO entered by this Court permit the Attorney General to (1) defend legal actions brought against state entities seeking to enforce Proposition 209, and permit the Governor to (2) continua the process of identifying I state affirmative action programs potentially affected by Proposition 209 Having considered all of the circumstances the Court grants these requests.

This Court will treat plaintiffs memorandum in support of their Application for TRO as their opening brief in support of their Motion for Preliminary Injunction Defendants and Defendant-Intervenor she I file their opposition thereto no later then Friday, December 6, 1996. Plaintiffs shall file their reply, it any, no later than Wednesday, December 11, 1996 at noon.[9l

IT IS FURTHER ORDERED that plaintiffs Motion to Certify a Defendant Class shall be heard on Monday, December 16, 1996 at 10:00 a.m. in Courtroom 5 [103 Defendants' opposition to said motion shall be filed no later then Friday, December 6, 1996. Plaintiffs' reply thereof it any, shall be filed no later then Wednesday, December 11, 1996 at noon.

IT IS FURTHER ORDERED that all papers filed in connection with this Order shall be hand-served or faxed on opposing counsel

IT IS SO ORDERED
Date: 11.12. 96
Signed by Thelton E. Henderson, Chief Judge
United States District Court


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Carl Gutierrez-Jones
Department of English
University of California, Santa Barbara
E-mail: carlgj@humanitas.ucsb.edu