HomeMy WebLinkAboutAGENDA REPORT 2025 0917 CC REG ITEM 09BCITY OF MOORPARK, CALIFORNIA
City Council Meeting
of September 17, 2025
ACTION RECEIVED AND FILED.
BY A. Hurtado.
B. Receive Update on Federal Immigration Enforcement Activities. Staff
Recommendation: Receive and file report. (Staff: Kevin G. Ennis, City Attorney)
Item: 9.B.
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MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Kevin G. Ennis, City Attorney
DATE: 09/17/2025 Regular Meeting
SUBJECT: Receive Update on Federal Immigration Enforcement Activities
SUMMARY
On July 9, 2025, Kelley Smith sent an email to the City asserting that the City had a legal
duty to stop armed, private immigration contractors operating within Moorpark city limits
because those contractors are carrying weapons and not wearing appropriate
identification in violation of certain state gun laws and laws prohibiting the impersonation
of peace officers. Ms. Smith’s assertions were mentioned during the City Council meeting
on July 16, 2025. Staff was asked to evaluate her assertions and provide a public agenda
report responding to them at a future date.
For the reasons noted in this report, the City is immune from liability if the City does not
intervene in the operations of federal immigration contractors, and would likely be legally
enjoined from the type of intervention Ms. Smith recommends even if federal immigration
contractors are not abiding by state gun or peace officer identification laws. Rather than
have the City take the actions Ms. Smith advocates, state and federal legislation has been
introduced to address some of these issues. In addition, there is a federal court case
being litigated by other parties that are intended to address some of the issues and
concerns raised by Ms. Smith’s emailed comments.
BACKGROUND
Ms. Smith’s email asserts that individuals employed by G4S, a private company and
subsidiary of Allied Universal, are not sworn United States Immigration and Customs
Enforcement (ICE) agents or federal law enforcement, and that these individuals are
patrolling public spaces in tactical gear and carrying weapons without any visible
credentials. The email further asserts that these contractors are operating in Moorpark
hotel parking lots, commercial centers and in other neighborhoods across Ventura County
and that these individuals are not trained, deputized, or authorized to carry firearms
pursuant to the requirements of California state law. The email goes on to assert that “If
Item: 9.B.
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one of these private contractors … harms, detains, or shoots someone and this city fails
to act after constructive notice, the result is: -Foreseeable harm -Negligence in duty of
care -Direct liability for the city and potentially for you as elected officials.”
Based on these assertions and arguments, Ms. Smith has asked the City Council to take
a series of actions to instruct the City’s police officers (Ventura County Sheriff’s Office) as
follows:
Direct Law Enforcement to Identify and Document These Contractors
•Request Proof of [Bureau of Security and Investigative Services] guard
cards and California firearm permits
•Confirm whether any sworn federal agent is present
•Determine legal basis for public weapon carry in your city
Instruct Officers to Treat Uncredentialed Armed Individuals as Armed Civilians
•Investigate under Penal Code 538d and local weapons laws
Establish a Public Reporting Protocol
•Armed individuals without ID
•Unmarked or mismatched license plates
•Reports of intimidation or false detentions
Ms. Smith further asks the City Council to:
Direct the City Attorney to Issue a Hotel Liability Advisory
•Require verification of armed guests’ lawful status
DISCUSSION
A.Potential for City Liability.
Ms. Smith’s email makes several assertions about potential liability for the City and
elected officials individually. The basic premise of Ms. Smith’s assertions is that by
allowing federal government contractors to allegedly violate state laws regarding the
carrying of weapons and the impersonation of peace officers, the City and individual
councilmembers are allowing crimes to occur in the City and because she has now put
the City on notice of these alleged crimes, the City is civilly liable for the injuries incurred
by residents on account of the activities of these contractors if the City does not take
action to stop the alleged violations of state law.
Even if these immigration enforcement contractors are violating state law, an assumption
we have neither validated nor invalidated, the City of Moorpark and Moorpark
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Councilmembers are not civilly liable for the actions of these federal contractors. This is
because state law provides broad and general statutory immunity from the failure to stop
crime occurring within the City.
The California Government Claims Act makes public agencies immune from liability for
failing to enact or enforce a law, failing to provide police protection service, or failing to
make an arrest (See Government Code Sections 818.2, 845, 846.). Together, these
statutes mean that cities cannot be held civilly liable if a crime is committed in the City
and the City failed to have police officers dispatched to prevent that crime.
Further, with respect to claims that councilmembers are individually liable, Government
Code Section 820.9 provides that councilmembers and mayors are not vicariously liable
for injuries caused by the act or omission of the public entity, and Government Code
Section 821 provides that public officers are not liable for an injury caused by their
adoption of or failure to adopt an enactment or by their failure to enforce an enactment.
Furthermore, as explained more fully later in this report, when such contractors are
performing the federal government’s detention operations, they are immune from state,
and, by extension, municipal control. Accordingly, the City cannot be liable for failing to
take what would qualify as an unconstitutional action.
B.City’s Legal Ability to Intervene in Federal Immigration Enforcement
Activities.
Moving past the threat of City liability for failure to intervene in federal immigration
enforcement activities, there is a substantial question as to whether the City even has the
legal ability to undertake the actions requested by Ms. Smith. This is because the City
and state, are largely precluded from restricting federal government activities, including
activity of federal contractors. For example, the Ninth Circuit Court of Appeals invalidated
A.B. 32 (2019), which prohibited ICE’s contractors from running detention facilities. The
court declared: “Whether analyzed under intergovernmental immunity or preemption,
California cannot exert this level of control over the federal government’s detention
operations” [Geo Group, Inc. v. Newsom, 50 F.4th 745, 751 (2022)].
The reporting actions that Ms. Smith requests the City to undertake could subject the City
and its employees to federal enforcement actions against the City and the employees
involved. Recently, the Santa Ana City Council considered a policy to provide public
notice of ICE operations. In response, the U.S. Department of Justice sent a June 6,
2025, letter warning that impeding ICE’s work will result in criminal prosecutions for
interfering in the enforcement of federal immigration laws.
The direction that Ms. Smith wants the City Council to provide to the Sheriff’s Office is
also inconsistent with the “Agreement for County to Perform Certain Services and
Functions for the City of Moorpark” entered into on June 6, 1984, between the City and
County of Ventura. In that Agreement, it is clear that the direction, supervision, standards
of performance of Sheriff’s personnel and all other matters incidental for the delivery of
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general law enforcement services to the City are determined by the Sheriff, who retains
exclusive authority over the activities of personnel working in the City. If the City Council
were to direct the Sheriff to implement Ms. Smith’s requests, the City would likely be
overstepping its role and authority in its contractual arrangement with the Sheriff.
This is not to say that there are not legitimate questions as to a clash of state versus
federal laws, and more particularly, issues of U.S. Constitutional compliance raised by
the manner in which these immigration enforcement contractors are conducting their
activities. As more fully explained below, these clashes are being addressed in the courts,
in Sacramento and in Congress.
As it relates to the issues addressed, Chief Odenath has stated that the Moorpark Police
Department responds, and will continue to respond, to calls for service related to
individuals who may be impersonating a law enforcement officer or reports of a possible
kidnapping. The Moorpark Police Department encourages anyone who believes they are
witnessing one of these crimes, or any crime, to call 911 immediately.
C.Request for Liability Advisory to Hotels.
The email also asserts that hotels “are exposed under the Innkeeper’s Act” by allowing
these contractors to be guests in their hotels and suggests that the Council direct the City
Attorney to issue a hotel liability advisory.
First, the City Attorney is retained by the City, and does not provide legal opinions about
potential liability to third parties, such as hotels. Thus, it would not be appropriate for the
City Attorney to provide legal advice to hotels in how they should comply with state laws.
The State Attorney General’s Office would be the more appropriate entity to do so, if at
all.
Second, even if the City Attorney were to provide such a hotel liability advisory opinion,
the contention that this situation creates liability exposure for hotels under the Civil Code
Section 1859 et seq. may not be correct. In key part, Civil Code Section 1859 et seq.
addresses an innkeeper’s liability for losses to a guest’s personal property such clothes,
suitcases and jewelry if and when such property is lost or stolen while the person is a
guest of the hotel. That law does not address an innkeeper’s duty to preclude certain
persons from occupying a guest room or verifying the guests identify for purposes of
excluding those guests.
D.Proposed Legislation and Pending Litigation Relating to Recent Immigration
Enforcement Activities.
We understand that Ms. Smith and others have concerns with respect to federal agents
conducting enforcement activities without identification and potentially in violation of state
and federal laws and Constitutional requirements. As a result, there is proposed federal
and state legislation pertaining to immigration enforcement activities, including:
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•S 2212 (Padilla)/HR 4667 (Gonzalez). This bill would amend Section 287 of the
Immigration and Nationality Act to mandate that all immigration enforcement officers
display visible identification during public-facing enforcement actions.
•HR 4004 (Velazquez). This bill would require that immigration enforcement agents not
wear facial coverings during enforcement operations and display name/affiliation on a
visible garment. It would further provide exemptions when responding to imminent
threats and/or for safety/medical reasons.
•SB 627 (Weiner). This bill would make it a misdemeanor for any law enforcement
officer to wear masks or personal disguises that obscure their identity while interacting
with the public. It would further provide exemptions for medical masks, protective gear
for hazardous situations and SWAT/undercover operations. It would also require that
agencies planning operations likely to involve masked personnel to notify local law
enforcement at least 12 hours in advance of the location, time and length of the
operation.
•SB 805 (Perez). This bill would require law enforcement officers operating in California
to visibly display identification when performing enforcement duties. It would further
provide exemptions for undercover activities.
Additionally, a case was filed in Federal District Court (Vasquez Perdomo v. Noem) that
relates to the use of “suspicionless” immigration enforcement activities and stops. On
July 11, 2025, the Federal District Court for the Central District of California, which covers
portions of southern and central California including Ventura County, issued a temporary
restraining order (“TRO”) which, in part, prohibited immigration agents from stopping
individuals without reasonable suspicion and from relying on four factors – alone or in
combination – including apparent race or ethnicity; speaking Spanish or English with an
accent; presence in a particular location like a bus stop, car wash, or agricultural site; or
the work the person does. On August 1, 2025, the Ninth Circuit Court of Appeals denied
the federal government’s request for a stay. On August 7, 2025, the Department of
Justice filed a motion to the U.S. Supreme Court for a stay of the District Court’s TRO.
On September 8, 2025, the Supreme Court granted the federal government’s application
for a stay pending the appeal in the Ninth Circuit of the District Court’s injunction. This
means that that the federal government is not bound by the TRO while the Ninth Circuit
considers the appeal of the TRO. The case remains active.
In summary, the City does not have a legal duty to intervene in federal immigration
enforcement activities, will not be civilly liable if it fails to intervene, could expose itself to
federal law enforcement actions if it does intervene, and would be contradicting its
contractual agreement with the Sheriff’s Office if it does intervene in the manner
requested by the public comment. The court case of Vasquez-Perdomo v. Noem is a
venue in which many of the underlying concerns about federal immigration enforcement
actions are being addressed with respect to compliance with state, federal and
Constitutional law. In addition, state and federal legislation is also pending to also
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address some of the other issues raised by the comments regarding masks and
identification.
ENVIRONMENTAL DETERMINATION
This action is exempt from the California Environmental Quality Act (CEQA) as it does
not constitute a project, as defined by Section 15378 of the State CEQA Guidelines.
Therefore, no environmental review is required.
FISCAL IMPACT
None.
COUNCIL GOAL COMPLIANCE
This action does not support a current strategic directive.
STAFF RECOMMENDATION
Receive and file report.
Attachment: July 9, 2025, Public Comment from Kelley Smith
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Not DHS
Not police
Not peace officers under California law
They are CONTRACTORS from G4S (a subsidiary of Allied Universal). ICE contracts with these two private
companies for transportation and detention contracts. They do not contract for enforcement authority (nor can
they).
This is not speculation. Their contract is on the GSA website. You can also google: ICE and HSI contracts with
either firm.
We have photos, license plates and firsthand reports on these contractors operating vehicles without license
plates, switching license plates, different plates on the front vs the back.
We have documented video and photographic evidence of contractors from these 2 private companies (G4S &
Allied Security) committing assaults, posing as law enforcement and carrying out other crimes.
These men are operating, unchecked, in Moorpark hotel parking lots, commercial centers and in other
neighborhoods across Ventura and LA counties.
Why This Matters Under California Law
These contractors from G4S and Allied Security are not trained under California POST.
They are not deputized and cannot be deputized under SB 54 and California Attorney General guidelines.
They do not qualify as peace officers under Penal Code 830.
To legally carry firearms in public in California, a person must:
Hold a valid BSIS guard card
Possess a CA firearm permit
Be actively working for a licensed entity with legal public carry authority
Be under the direct supervision of a sworn federal agent, physically present on scene
These men (in our area) are operating alone. No visible FEDERAL agents. No supervision. That makes them
armed civilians under California law and subject to state prosecution.
And this means this city and our sheriff’s dept are not “impeding a federal investigation or action” if they
intervene or cite these contractors for breaking the law.
Because that’s not who this is.
These are not federal employees in the eyes of the law (and their own contract). They are private individuals
working for a private company.
Think Blackwater. Iraq. Early 2000s. Remember how that turned out?
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After the 2007 Nisour Square massacre, four Blackwater contractors were prosecuted under the Military
Extraterritorial Jurisdiction Act (MEJA) and convicted of manslaughter and weapons charges — even though
they were working under a U.S. State Department contract.
The law was clear then and still stands now: being a federally funded contractor does not give you immunity.
The same applies here. If private immigration contractors are illegally armed, impersonating agents, or violating
civil rights, then they, and the companies deploying them, can be held criminally and civilly liable under
California and federal law. Just like Blackwater.
They Cannot Be Deputized in California
Well what if ICE or HSI just deputized them? Deputization has to happen by a local entity. There is no lawful
path for the LA, Ventura County Sheriff or any local department to deputize these individuals because of
existing laws already on the books preventing this.
Under Gov. Code 7284.6(a)(1) (California Values Act, SB 54), CA law enforcement is:
Prohibited from using city resources to assist in civil immigration enforcement
Prohibited from entering into 287(g) or similar agreements
Required to treat private immigration contractors as civilians — not law enforcement
Even if DHS wanted to ask our sheriff’s department to deputize them, California law preempts it. This was
upheld in United States v. California (921 F.3d 865), confirming California’s right to restrict local cooperation.
The Only Exception (Which Is Not Happening)
If a sworn ICE or HSI agent is physically present, with these private contractors and directing the action, then
contractors may legally support an operation.
But:
There is no visible federal supervision here in the Conejo valley operations
There are no badges, IDs, or marked vehicles
These men are acting on their own
Without a sworn FEDERAL agent on-site, they are impersonating law enforcement and carrying weapons
illegally.
Under California law, that triggers:
Penal Code 538d – Impersonating a peace officer
Penal Code 207 – Kidnapping
Penal Code 25400 – Carrying a concealed firearm without a permit
Penal Code 25850 – Carrying a loaded firearm in public
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Legal Exposure to the City
If one of these private contractors from G4S or Allied Security, harms, detains, or shoots someone and this city
fails to act after constructive notice, the result is:
Foreseeable harm
Negligence in duty of care
Direct liability for the city and potentially for you as elected officials
Additionally: Hotels housing these men may also be liable under the California Innkeeper’s Act (Civil
Code 1859–1865) for failing to verify authority or protect other guests and employees from armed individuals.
What’s happening in Moorpark directly impacts the economic health of the region:
Families are canceling hotel stays
Visitors are avoiding retail zones
Fear is reducing foot traffic
Local businesses are seeing economic impact without understanding the cause
This will show up in Transient Occupancy Tax (TOT) and sales tax data, but by then, the damage will be done.
And if businesses or their customers are harmed either physically, mentally or economically and it can be
shown the city or business community had constructive notice and failed to act, there is legal exposure.
5 Actions City Council Can Take Now
1. Direct Law Enforcement to Identify and Document These Contractors
o Request proof of BSIS guard cards and California firearm permits
o Confirm whether any sworn federal agent is present (they aren’t)
o Determine legal basis for public weapon carry in your city
2. Instruct Officers to Treat Uncredentialed Armed Individuals as Armed Civilians
o A 911 call for a man with a gun and no badge assaulting someone is not presumed to be ICE; it
should be treated as an emergency by this city and the sheriff department it contracts with
o Investigate under Penal Code 538d and local weapons laws
3. Direct the City Attorney to Issue a Hotel Liability Advisory
o Hotels are exposed under the Innkeeper’s Act
o Require verification of armed guests’ lawful status
4. Establish a Public Reporting Protocol
o Armed individuals without ID
o Unmarked or mismatched license plates
o Reports of intimidation or false detentions
5. Agendize This Issue for Your Next Meeting
o I formally request you place this item on the public agenda:
Investigation of armed immigration contractors operating in Moorpark and legal compliance with state law, municipal
code, and liability under the California Innkeeper’s Act.
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This council has the legal authority and responsibility to enforce California law and protect our community
from the physical harm AND the economic damages these raids are creating.
History shows us that Southern US cities in states like Virginia, Alabama & Arkansas once used every tool
available, local laws, bureaucracy and even defiance to resist federal civil rights enforcement.
If that kind of resistance worked to uphold INjustice, surely we can flip the script to uphold protection.
Our goal should be to make it legally impossible for these private immigration contractors to operate in our
cities without consequence.
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The loophole is federal. But the liability is local.
Now that you know, the only legal question is:
What will you do about it?
I’m available to meet with any of you to review federal contracts, images, reports, and legal codes.
Thank you for your time and public service.
Kelley Smith
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