Model Amicus Brief of Praxis Foundry in L.M.L. v. Martin: The Person Already Inside the Federal Immigration System

This artifact is a public model amicus brief written as if submitted in support of Plaintiffs’ Motion for Temporary Restraining Order and Preliminary Injunction in L.M.L. v. Martin, No. 1:26-cv-01170, in the United States District Court for the Western District of Texas, Austin Division. The brief has not been filed in any court and is not legal advice. A professional lawyer would need to adapt, verify, format, cite-check, and file any actual brief. The brief addresses whether Texas Senate Bill 4, as challenged, creates a parallel state criminal-removal system that treats federally recognized immigration status, pending federal process, federal protection, federal discretion, and federally governed consequences as though they disappear when a person is encountered by state law. The brief argues that the person is already inside the federal immigration system. Texas law must not pretend otherwise. It frames the constitutional injury as false object substitution: SB 4 substitutes a state criminal-removal object for the federally situated person. The brief does not deny that States possess real authority to enforce ordinary criminal law, protect public safety, and cooperate with federal officials where federal law permits. Its narrower claim is that a State may not create an independent removal system that treats the federal immigration relation as if it no longer exists. Using the Constitutional Physiology / Structural Flow / Federalism-as-scale-discipline / Constitutional Civic Field frame in translated form, the brief presents a court-facing argument for preserving person-continuity, federal status, federal process, federal protection, federal discretion, and federally governed consequence against state-law object substitution.