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AB 324 (California Values Act): Limits and Exceptions on Local Immigration Cooperation

Codifies a ban on local law enforcement assisting federal immigration enforcement in many ways, creates narrow operational exceptions, and mandates annual reporting from task forces and transfers.

The Brief

AB 324 amends the California Values Act framework by listing specific actions that California law enforcement agencies may not take to assist federal immigration enforcement, while carving out narrow, defined exceptions and new reporting requirements. It prohibits using public funds or personnel to investigate or act for immigration enforcement, forbids honoring hold requests or turning over people without judicial authorization, and bars deputization or dedicated office space for immigration authorities.

The bill also requires annual disclosures about joint task force activity and transfers to immigration authorities, directs the Attorney General to publish an annual summary of task force arrests, and preserves limited pathways for information sharing under federal statutes and for criminal investigations that meet tightly specified conditions. For local agencies, prosecutors, privacy officers, and compliance teams, AB 324 changes day-to-day cooperation rules with ICE and imposes new data and reporting obligations that will affect operations, interagency agreements, and public transparency.

At a Glance

What It Does

The bill forbids California law enforcement from using agency funds or personnel to perform immigration-enforcement activities listed in seven specific subpoints, prevents deputization as federal immigration officers, and restricts transfers to ICE except on judicial warrant or when a statutory exception applies. It creates reporting duties for agencies that participate in joint task forces and requires the Attorney General to publish an annual statewide report.

Who It Affects

County sheriffs, municipal police departments, state law enforcement agencies, joint task forces that combine federal and local officers, and the Department of Justice (Attorney General) which must receive and publish reports. It also implicates personnel administrators, records custodians, and legal counsels tasked with CLETS and TRUTH Act compliance.

Why It Matters

AB 324 tightens limits on local–federal cooperation and increases public transparency about task-force activity and transfers to immigration authorities, shifting operational burdens onto local agencies and the Attorney General while protecting immigrant-related privacy and local control over policing priorities.

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What This Bill Actually Does

The bill draws a bright line around what California law enforcement cannot do to help federal immigration enforcement. It lists concrete prohibitions: agencies may not use department money or staff to investigate or arrest people for immigration purposes; they may not ask about immigration status; they may not hold people on ICE “hold” requests; they may not hand over nonpublic personal information like home or work addresses; they may not make arrests based on civil immigration warrants; and they may not perform the duties of federal immigration officers or otherwise help execute federal immigration statutes.

Those prohibitions are not absolute. AB 324 allows specific activities that a local agency’s policy or local law permits.

It also sets narrowly tailored operational exceptions: local officers may enforce certain federal immigration crimes detected during unrelated law enforcement activity (notably particular 8 U.S.C. §1326 offenses with an enhancement) and may respond to ICE requests for criminal-history information through CLETS where state law permits. Participation in multiagency task forces is permitted so long as the task force’s primary purpose is not immigration enforcement and the local agency’s participation complies with its own policies.To create transparency, the bill forces reporting.

Any California agency dedicating personnel or resources to a joint task force must file an annual report to the Attorney General listing the task force’s purpose, partners, total arrests, and arrests made for immigration enforcement. Separately, all agencies must report annually the number of transfers to immigration authorities that occurred under the transfer exception and the underlying offense that justified the transfer.

These reports are public records under the California Public Records Act, though agencies may redact identifying details that would endanger people or investigations.Finally, the bill clarifies two persistent friction points. It preserves an agency’s ability to comply with federal statutes requiring information exchange (8 U.S.C. §§1373 and 1644) and it allows immigration authorities access to interview people in custody consistent with the TRUTH Act.

It also preserves a local agency’s authority to exercise criminal jurisdiction over alleged crimes — the statute is trying to limit immigration-driven activity without stripping agencies of their criminal-enforcement roles.

The Five Things You Need to Know

1

The statute expressly prohibits using agency funds or personnel to inquire about immigration status, detain on ICE hold requests, provide nonpublic personal information (like home or work addresses), make arrests based on civil immigration warrants, or perform immigration-officer functions.

2

Transfers to federal immigration authorities are allowed only with a judicial warrant or a judicial determination of probable cause, or as otherwise provided under Section 7282.5 of state law.

3

An exception permits local officers to investigate or arrest for certain 8 U.S.C. §1326 offenses detected during unrelated policing activity, but transfers in those cases still must meet the statute’s transfer authorization rules.

4

Agencies that dedicate personnel or resources to joint task forces must submit annual reports to the Attorney General listing task force purpose, partner agencies, total arrests, and arrests for immigration enforcement; the Attorney General must also publish an annual statewide summary.

5

The bill does not bar sending or receiving immigration- or citizenship-status information when permitted by federal law (8 U.S.C. §§1373 and 1644), preserving a narrow federal information-exchange pathway.

Section-by-Section Breakdown

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Subdivision (a)

Prohibited local actions aiding immigration enforcement

This subsection enumerates seven distinct categories of assistance that agencies may not provide for immigration enforcement purposes: using funds or staff for immigration investigations; asking about immigration status; detaining on hold requests; sharing nonpublic personal information; making arrests on civil immigration warrants; assisting with 8 U.S.C. §1357(a)(3) activities; and performing immigration-officer functions under 8 U.S.C. §1357(g) or similar arrangements. Operationally, agencies must audit policies, training, and contracts (including facility-sharing agreements) to ensure none of these activities are funded or staffed by local resources.

Subdivision (a)(2)–(a)(6)

Limits on deputization, facility use, and contracting

The bill forbids placing state or local peace officers under federal supervision for immigration enforcement or hiring deputies designated as federal immigration officers, and prohibits dedicating exclusive office space or contracting facilities to house federal immigration detainees except where an existing statutory chapter allows. Practically, this constrains memoranda of understanding, secondments, and local–federal co-location arrangements; agencies must examine existing MOUs and housing contracts for compliance or seek statutory exception routes.

Subdivision (b)

Permitted exceptions and narrow operational carve-outs

Subdivision (b) lists exceptions that do not violate the prohibition so long as they conform to agency policy and local law. They include enforcement of certain aggravated illegal reentry offenses (8 U.S.C. §1326 with enhancements) discovered during unrelated policing, responding to CLETS-based requests for criminal-history data, participating in joint task forces whose primary mission is not immigration enforcement, facilitating T- and U-visa certifications or gun-law background checks for noncitizens, and allowing interviews under the TRUTH Act. Each exception carries conditions — for example, task-force participation requires the agency’s policy alignment and that the task force’s primary purpose not be immigration enforcement — which will force agencies to document purpose and scope.

3 more sections
Subdivision (c)

Reporting requirements for task forces and transfers

Agencies that commit personnel or resources to ongoing joint task forces must file annual reports to the Attorney General containing, if known, the task force purpose, participating agencies, total arrests, and arrests made for immigration enforcement. Separately, every law enforcement agency must report annually the number of transfers to immigration authorities under the transfer permission and the offense that justified each transfer. Records subject to these reporting requirements are public under the California Public Records Act, although agencies may redact personal identifiers where disclosure would endanger individuals or investigations.

Subdivision (d)

Attorney General’s statewide reporting and publication

The Attorney General must assemble and publish an annual statewide report compiling arrests by joint task forces and arrests made for immigration enforcement by all task force participants, including federal partners. The statute directs the AG to post these reports online, creating centralized transparency but also obliging the Department of Justice to design templates, collection methods, and redaction rules to reconcile public disclosure with safety and investigative secrecy.

Subdivisions (e) and (f)

Federal information-exchange carve-out and retention of criminal jurisdiction

Subdivision (e) clarifies that the statute does not prevent sending to or receiving from federal immigration authorities information about a person’s immigration or citizenship status when done pursuant to 8 U.S.C. §§1373 or 1644, or from maintaining such information with other governmental entities. Subdivision (f) reinforces that nothing in the section limits a California agency’s authority to exercise criminal jurisdiction. These clauses preserve limited federal-state data flows and local criminal enforcement authority while the statute curtails immigration-driven policing.

At scale

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Undocumented immigrants and mixed-status families — by restricting routine local cooperation with federal immigration enforcement, the bill reduces the risk that ordinary interactions with police will trigger immigration action and aims to improve willingness to report crimes and cooperate with investigations.
  • Victims and witnesses of crime eligible for T or U visas — the statute permits the certification-related inquiries necessary for immigration relief and victim protections, making it easier for certain crime victims to pursue visas and cooperate without broader immigration entanglement.
  • Privacy and civil-rights advocates — they gain statutory constraints on sharing nonpublic personal data (like home and work addresses) and a public reporting regime that forces accountability on joint task-force activity.
  • Community policing efforts — by limiting immigration-focused enforcement, local agencies may strengthen trust in communities that otherwise avoid interacting with law enforcement.

Who Bears the Cost

  • Local law enforcement agencies (sheriff’s offices and municipal police departments) — they must revise policies, revise MOUs, train staff, track task-force activity, and compile annual reports for the Attorney General, creating administrative and budgetary burdens.
  • Sheriffs and prosecutors who want to cooperate with federal immigration authorities — the restrictions and the judicial-warrant requirement for transfers limit their operational discretion and may complicate prosecutions involving noncitizen suspects.
  • State Department of Justice (Attorney General) — it must design reporting templates, collect and publish data, and resolve redaction and privacy issues, adding ongoing administrative workload.
  • Federal immigration authorities (ICE) — they may see diminished local assistance, fewer detentions based on local holds, and reduced access to nonpublic local data, complicating removal operations relying on local cooperation.

Key Issues

The Core Tension

The central dilemma is whether and how to protect immigrant communities from federal immigration enforcement while preserving effective crime fighting and interagency cooperation: the bill protects privacy and community trust by restricting local assistance to ICE, but those same limits — plus reporting and disclosure obligations — create operational complexity, potential evidence gaps for federal prosecutions, and ambiguous boundaries that will demand administrative resources and judicial interpretation.

The bill strings together protection, operational exception, and transparency mechanisms that will generate practical and legal friction. The statutory list of prohibited activities is detailed, but the phrase “for immigration enforcement purposes” is fact-sensitive.

Distinguishing an activity done for immigration enforcement from routine criminal enforcement will require line-drawing in training, incident documentation, and potentially litigation. For example, an officer asking about nationality to establish identity or gang membership might be defensible in one context and prosecuted as an immigration inquiry in another.

The reporting and disclosure regime aims at transparency but creates risks and costs. Agencies must collect and publish arrest counts and transfer details, yet the statute also recognizes redaction needs where safety or investigatory integrity is at stake.

That balancing act will force the Attorney General and local agencies to adopt granular rules for what gets published, how to reconcile incomplete data (“if known” language), and how to standardize reporting across varied task forces. Operationally, the CLETS and 8 U.S.C. §1373/1644 carve-outs preserve some federal information flows, but they also import federal legal obligations and privacy risks into local systems, complicating compliance and potentially exposing jurisdictions to conflicting federal and state directives.

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