1

undermining Washington's sovereign interest in remaining a welcoming place for immigrants

2

and refugees. The Co urt should invalidate the portions of the Executive Order challenged here.

3

II.

JURISDI CTION AND VENUE

4

2. The C ourt has jurisdi ction pursuant to 28 U.S.C. §§ 1331 and 2201(a).

5

3.

Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b)(2) and

6

1391(e)(1). Defendants are United States agencies or officers sued in their official capacities,

7

and a substantial part of the events or omissions giving rise to this claim occurred in King

8

Coun ty, within the Western District of Washington .

9

II I. P A R T IES

10

4 .

The Governor is the chief executive officer of the State. The Governor is

11

responsible for overseeing the operations of the State and ensuring that its laws are faithfully

12

executed.

13

5.

The Attorney General is the chief legal adviser to the State. The Attorney

14

General's powers and duties include acting in federal court on matters of public conc ern.

5

6.

The State has declared that practices that discriminate against any of its

16

inhabitants because of race, creed, color, or national origin are matters of public concern that

17

threaten the rights and proper privileges of the State and harm the public welfare, health, and

18

peace of the people.

See

Wash. Rev. Code 49.60.010.

19 7.

The State's interest in protecting the health, safety, and well-b eing of its

20

residents, including protecting its residents from harms to their physical or economic health, is

21

a quasi-sovereign interest.

22 8.

The State also has an interest in ensuring that its residents are not excluded from

23

the benefits that flow from participation in the federal system, including the rights and

24 privileges provided by the U .S. Constitution and federal law.

25

26

COMPLAINT

2

ATTORNEY GENERAL OF W ASHINGTON

800 Fifth Avenue, Suite 2000 Seattl e, WA 98104-3188 206)464-7744