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On March 24, 2020, in City of Providence v. Barr, the U.S. Court of Appeals for the First Circuit held that the Department of Justice lacked statutory authority to impose immigration-related conditions on Edward Byrne Memorial Justice Assistance Grants awarded to Providence and Central Falls, Rhode Island. As the most recent of five circuit courts to consider this issue, the First Circuit squarely rejected the Second Circuit’s holding that the challenged conditions were statutorily authorized. Instead, the First Circuit sided with the Seventh, Third, and Ninth Circuits in striking down the challenged conditions. Although the First Circuit reached the same ultimate conclusion as the Ninth Circuit, it used an alternate reasoning. This Comment argues that the First Circuit in Providence v. Barr correctly interpreted the text and structure of the statutes at issue and respected congressional intent, thus serving as a useful model for future courts confronted with this question.


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7 Sep 2022
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  • Subject
    • Immigration Law

    • President/Executive Department

  • Journal title
    • Boston College Law Review

  • Volume
    • 62

  • Issue
    • 9

  • Pagination
    • E.Supp. II.-102

  • Date submitted

    7 September 2022

  • Additional information
    • Suggested Citation:

      Heather Odell, Comment, Are Sanctuary Cities Safe? Evaluating the DOJ’s Authority to Impose Immigration Conditions on Criminal Justice Grants, 62 B.C. L. REV. E. SUPP. II.-102 (2021),