STATE OF FLORIDA v. STATE OF CALIFORNIA and STATE OF WASHINGTON - Motion for Leave to File a Bill of Complaint

Sep 18, 2026

Uploaded by Ezra

Motion for leave to file a bill of complaint in the U.S. Supreme Court by the State of Florida against California and Washington. Florida alleges the defendants openly defy federal immigration laws and resist federal enforcement. The filing focuses on alleged failures to comply with federal safety and immigration-status requirements for commercial driver’s licenses (CDLs), resulting in unsafe commercial driving across state lines. Florida claims the harmful effects extend to following states and cites a Florida highway incident involving an allegedly improperly licensed driver.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages33

Reading Time1 h 23 min

AccessFree to download

MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT

Bill of Complaint

Jurisdictional Statement

Factual Allegations

Florida’s Claims

Prayer for Relief

No , Original In the Supreme Court of the United States STATE OF FLORIDA, Plaintiff, v. STATE OF CALIFORNIA and STATE OF WASHINGTON, Defendants. MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT AND PROPOSED BILL OF COMPLAINT JAMES UTHMEIER Attorney General DAVID DEWHIRST Chief Deputy Attorney General JEFFREY PAUL DESOUSA Acting Solicitor General Counsel of Record JASON J. MUEHLHOFF Chief Deputy Solicitor General SAMUEL F. ELLIOTT Deputy Solicitor General ALLEN HUANG Deputy Solicitor General CHRISTINE PRATT Assistant Solicitor General CALEB STEPHENS Assistant Solicitor General OFFICE OF THE ATTORNEY GENERAL PL-01, The Capitol Tallahassee, FL 32399 (850) 414-3300 jeffrey.desousa@ [myfloridalegal.com](myfloridalegal.com) October 2025 Counsel for Plaintiff TABLE OF CONTENTS MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT ....................................................................... 1 BILL OF COMPLAINT .......................................................2 JURISDICTIONAL STATEMENT..................................... 3 FACTUAL ALLEGATIONS ................................................ 4 A. Federal Authority and Law Governing Commercial Driver’s Licenses ....................................4 1. Congress and the Department of Transportation extensively regulate commercial vehicle licensing and safety.............. 5 2. The States are required to implement extensive safety testing standards and to ensure applicants provide citizenship documentation.......................................................6 3. States face serious punishment for noncompliance ........................................................... 10 B. California and Washington Ignore These Obligations by Passing “Sanctuary” Laws Prohibiting State Agencies from Inquiring into Immigration Status .................................................. 10 1. California’s commercial licensing scheme and failures................................................................. 10 2. Washington’s commercial licensing scheme and failures ......................................................... 13 C. California’s and Washington’s Failures Severely Harm Florida and Other Law-Abiding States ........ 15 FLORIDA’S CLAIMS ........................................................23 PRAYER FOR RELIEF .....................................................29 No , Original In the Supreme Court of the United States STATE OF FLORIDA, Plaintiff, v. STATE OF CALIFORNIA and STATE OF WASHINGTON, Defendants. MOTION FOR LEAVE TO FILE A BILL OF COMPLAINT The State of Florida moves the Court for leave to file the accompanying Bill of Complaint. In support of its motion, the State asserts that its claims arise under the United States Constitution; its claims are serious and dignified; and there is no alternative forum to provide adequate relief. JAMES UTHMEIER Attorney General DAVID DEWHIRST Chief Deputy Attorney General JEFFREY PAUL DESOUSA Acting Solicitor General Counsel of Record JASON J. MUEHLHOFF Chief Deputy Solicitor General SAMUEL F. ELLIOTT Deputy Solicitor General Respectfully submitted, ALLEN HUANG Deputy Solicitor General CHRISTINE PRATT Assistant Solicitor General CALEB STEPHENS Assistant Solicitor General OFFICE OF THE ATTORNEY GENERAL PL-01, The Capitol Tallahassee, FL 32399 No , Original In the Supreme Court of the United States STATE OF FLORIDA, Plaintiff, v. STATE OF CALIFORNIA and STATE OF WASHINGTON, Defendants. BILL OF COMPLAINT The State of Florida, by and through its Attorney General, James Uthmeier, brings this suit against Defendants, the State of California and the State of Washington, and for its claims for relief states: 1. California’s and Washington’s open defiance of federal immigration laws is well-documented. Both States routinely frustrate and hinder federal law enforcement from addressing the immigration crisis and the des

FAQs

What is the motion asking the U.S. Supreme Court to do?

The State of Florida asks for leave to file the accompanying Bill of Complaint.

What legal basis does Florida cite for the Court’s jurisdiction?

Florida asserts the Court has original jurisdiction over controversies between States under Article III, Section 2, Clause 2, and that Title 28, Section 1251(a) makes it exclusive.

What failures does Florida allege regarding commercial driver’s licenses (CDLs)?

Florida alleges California and Washington failed to honor federal safety regulations tied to CDLs and immigration-status standards, leading to authorization of drivers Florida claims lack proper training or ability to read road signs.

Sep 18, 2026

Uploaded by Ezra