Cotati City Council &
Community-Police Advisory
Committee
Agenda Staff Report
Item type: REGULAR AGENDA (ACTION)
To: City Council & Community-Police Advisory Committee
Subject: SUMMARY OF LOCAL GOVERNMENT POLICIES TO
ADDRESS COMMUNITY SAFETY DURING IMMIGRATION
ENFORCEMENT ACTIONS AND RECOMMENDATIONS FOR
LOCAL POLICIES
Date: March 24, 2026
Written by: Damien O’Bid, City Manager
Recommendation
It is recommended that the Cotati City Council and Community Police Advisory Committee discuss potential actions or policies, if any, that may best protect the community in the event of federal immigration intervention in Cotati.
Background
At the March 10, 2026 City Council meeting, the City Council requested that staff research what other jurisdictions are doing from a policy perspective to maintain trust and protect community safety before and during immigration enforcement operations and bring back options for discussion at the next (March 24) City Council meeting. This is particularly true when these enforcement operations are broader in scope than just arresting criminals and use inflammatory and aggressive tactics, such as what was seen most recently in Minneapolis. In addition to generally researching policy options, it was requested that staff look at the Denver policy that was mentioned during public comment, review the proposed ordinance provided by citizens during public comment as well as an ordinance from the Sanctuary Coalition of Sonoma County.
Furthermore, the City Council requested that the Community-Police Advisory Committee (Committee) join the City Council in a joint discussion, if a quorum of the Committee members is available.
Immigration Enforcement in Minneapolis
Staff initially reviewed what happened in Minneapolis, where in early 2026 “Operation Metro Surge” put on a display of aggressive and troubling immigration tactics, initiating a national conversation. During and following Operation Metro Surge, the City of Minneapolis and the State of Minnesota have taken legal and local administrative actions to restrict federal immigration enforcement. More specifically, these actions include:
• Local Restrictions and Safety Zones:
o "ICE-Free Zones" Ordinance: Minneapolis Mayor Jacob Frey codified an executive order banning U.S. Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) from using city-owned properties, such as parking lots and garages, for staging operations.
o Prohibiting Information Sharing: Minneapolis Police Department (MPD) maintained policies not to participate in or assist with civil immigration enforcement, even as other agencies in the state operated under 287(g) agreements allowing voluntary “deputization”.
• Legal Action:
o Federal Lawsuit: The City of Minneapolis, along with other cities and the state, sued the federal government. The suit argued that immigration enforcement activities violated the Tenth Amendment, specifically that they commandeered local police resources, caused chaos, and disrupted city functions. • Legislative and Protective Measures:
o Sanctuary Policy Proposals: State lawmakers introduced bills aimed at restricting local law enforcement from cooperating with federal agents, attempting to make Minnesota a "sanctuary state". However, to date, no legislation has been signed into law.
o Protected Locations: Legislative efforts (e.g., HF 3435 for school sites) were introduced by Minnesota to prevent immigration enforcement from operating at "sensitive locations" such as schools, hospitals, and churches. o Driver’s Licenses for All: In 2023, the Minnesota enacted legislation allowing undocumented residents to obtain driver’s licenses.
In researching policy options for City Council consideration, staff included relevant actions taken by the State of California that help establish the context of our statewide laws, as well as various recent actions by cities and counties in California. While not necessarily operating under similar state laws, staff also included the actions by Denver (as requested on March 10) as well as Chicago. The following is a brief summary of actions by mechanism and jurisdiction:
• State of California
o The California Values Act (SB 54), effective since January 1 2018, serves as a baseline by restricting the use of state and local resources for immigration enforcement purposes. Local jurisdictions may only assist federal immigration authorities when authorized by a judicial warrant, or to share information regarding individuals with specific prior convictions (e.g., serious/violent felonies).
o The California TRUTH Act (AB 2792), effective since January 1, 2017, mandates that local jails provide inmates with written consent forms before U.S.
Immigration and Customs Enforcement (ICE) interviews, requires notification of release dates given to ICE, and compels annual community forums. o TRUST Act (AB 4), prohibits local law enforcement from detaining individuals on the basis of an ICE hold alone once they are eligible for release, except in certain cases where the individual has been charged with or convicted of specific serious crimes. This ensures that individuals are not held in custody simply due to their immigration status.
o The California Duty to Intercede Law (AB 26), built upon previous regulations (AB 392 and AB 1022), requires that police officers have a duty to intercede.
This law took effect on January 1, 2022 and requires that police officers immediately report and intercede when witnessing other officers using excessive force that is “clearly beyond that which is necessary.” Intercede includes physically stopping the excessive force, recording it if equipped with a camera, and reporting the incident to a superior. Failure to intervene can lead to serious disciplinary action, including the revocation of an officer's certification. o The No Secret Police Act (SB 627), passed in September 2025 and signed by Governor Newsom, bans federal and local officers from wearing masks to hide their identity, with exceptions for medical needs (N95s), safety equipment, or certain undercover work. However, this law is currently on hold, as a federal judge temporarily blocked the law in February 2026, finding that it likely violated the Constitution by selectively targeting federal agents while not applying equally to state law enforcement.
• Resolutions (Outside Sonoma County)
o Alameda County: Adopted a resolution (2026) to establish a policy prohibiting the use of county-owned or controlled property — including parking lots and nonpublic building areas—for federal staging, processing, or operations (Exhibit 1) o City of San Jose: Adopted a resolution (2026) establishing Council Policy 7-15, which prohibits the use of city parking lots, garages, and vacant lots for immigration staging or processing (Exhibit 2).
o City of Santa Clara. In early February 2026, the Santa Clara City Council adopted by Resolution City Council Policy 056 that prohibits the use of Cityowned or controlled parking lots, garages, open spaces, or other facilities as staging areas, processing locations, or operational bases for civil immigration enforcement (Exhibit 3).
• Ordinances (Outside Sonoma County)
o City of Berkeley: Enacted Ordinance No. 7,984-N.S. (2025), codifying its sanctuary policies into Municipal Code Chapter 13.114. It expands protections by prohibiting the disclosure of "protected personal information" and requiring public reporting of ICE requests (Exhibit 4).
o City of Richmond: Passed an ordinance (2025) adding Chapter 2.30 to its Municipal Code. It limits the use of city personnel and facilities for federal immigration enforcement and restricts sharing personal information unless legally mandated (Exhibit 5).
o City and County of San Francisco: Proposed an Ordinance to amend its Administrative Code (Section 4.19) to explicitly state that civil immigration enforcement is not a "City purpose" for the use of city property and authorizes the City Attorney to bring cause of action against any person or entity that uses City property for unlawful purposes.
o Santa Clara County: In October 2025, the Board of Supervisors directed staff to follow Chicago’s example and draft an ordinance or administrative policy restricting the use of county-owned property for civil immigration enforcement staging areas, processing locations or operations bases, absent lawful court orders.
Additionally, this included posting signage on public properties and making signs available to private property owners and reporting protocols for County staff to report any federal attempts to use County-owned or controlled properties. The status of this protocol is not known to City staff. Like Sonoma County, Santa Clara County is also using it’s social services funding to provide assistance for legal defense fund for undocumented immigrants.
• Executive Orders (Out of State Agencies)
o City of Chicago: Issued two Executive Orders: No. 2025-8 (Exhibit 6) prohibits using city property for immigration staging or processing, while Executive Order No. 2026-1 (Exhibit 7) defines police protocols for documenting federal enforcement and rendering medical aid at scenes.
o City and County of Denver: Issued Executive Order No. 152 (2026), which restricts the use of city property, mandates the use of body-worn cameras to record federal actions, and establishes de-escalation protocols to protect peaceful protesters (Exhibit 8).
Recent Actions by Sonoma County Agencies
Staff are aware of recent activity by the County of Sonoma, City of Petaluma, and City of Santa Rosa. It is believed that Healdsburg joined a lawsuit against the federal government regarding its sanctuary city policies. The following is the current status:
Santa Rosa
In 2017, the City of Santa Rosa declared itself an “Indivisible City” (Exhibit 9) and has more recently also joined a lawsuit against the federal government to challenge the designation of "sanctuary jurisdictions".
In February of this year, Santa Rosa adopted a resolution urging Congress to reform federal agent conduct regarding transparency and identification and is preparing an ordinance to prohibit federal agents from using city properties for staging or processing (Exhibit 10).
Currently, the Santa Rosa is proposing an ordinance following the San Francisco model to limit access to public property, but at the time of this staff report, it is unknown what action the Santa Rosa City Council will take. However, the published agenda for the March 24, 2026 City Council meeting proposes the introduction of an ordinance to prohibit unauthorized use of real or personal property belonging to the City. It further states that, “The use of City property to assist in the enforcement of Federal civil immigration law is not a City purpose.” There is no signage, noticing, or reporting requirements, but it does authorize the City Attorney to bring injunctive or other civil relief against the federal government. (Exhibit 11) Petaluma
In 2025, the City passed a resolution supporting SB 54 and re-affirming police policies stating that they would not hand over undocumented immigrants to federal authorities unless a serious crime has been committed (Exhibit 12). Petaluma also joined a lawsuit against the federal government to challenge the designation of "sanctuary jurisdictions".
County of Sonoma
In 2025, the County of Sonoma adopted Resolution No. 25-0015 (2025) to affirm its commitment to immigrant civil rights. (Exhibit 13). The County of Sonoma also formed a “Supporting Immigrant Communities Ad Hoc” in August 2025. As of January 27, 2026, the Ad Hoc had met eight times with the following status on initiatives provided to the Board of Supervisors:
• Support for Immigrant Communities County-Hosted Website - This public website was created to provide information to community members about County and other local resources. Information can be found regarding legal and social services, the North Bay Rapid Response network, as well as information about this Ad Hoc, including the Charter and meeting agendas and minutes. The website has also been shared with County staff as a resource they may share with clients or community members and is also linked from the City of Cotati website. <https://sonomacounty.gov/administrative-support-and-fiscalservices/county-executives-office/projects/support-for-immigrant-communities>
• Employee Protocols and Guidance for ICE Interactions - The Ad Hoc updated these protocols to include community feedback received. The protocols were released to staff County-wide in September 2025.
• Employee Training on ICE Protocols - The Ad Hoc directed the implementation of training for County staff on these protocols. The County held two trainings, in December 2025 and January 20226. County staff report that the training recording will be made available to all staff who may have been unable to attend. • Ensuring Public/Private Space Delineations - Ensuring County facilities clearly delineate public lobby and access space and employee-only, private space which is not accessible to the general public. Departments were required to report compliance to the County Executive.
• Regional Coordination and Preparedness - The Ad Hoc and staff are participating in the Belonging the Bay Initiative, a consortium of 12 Bay Area counties that meet monthly to discuss regional preparedness efforts related to a potential large-scale immigration enforcement event. The County hosted the next meeting later early this year. • Developed a Local Immigration Enforcement Response Plan - The Department of Emergency Management has developed a draft Local Immigration Enforcement Impact CONOP (Concept of Operations) which addresses the County’s response, in partnership with local providers, to a large-scale immigration enforcement event. The Draft is currently being reviewed by impacted external community stakeholders and is not yet available to other agencies or the public.
• Urgency Ordinance Prohibiting Law Enforcement Officers from Concealing Their Identity and Requiring Them to Present Identification and Agency-Identifying Insignia When Conducting Operations in the Unincorporated Areas of Sonoma County - On September 23, 2025, this draft Urgency Ordinance was considered by the Board of Supervisors. Following Board direction, staff initiated the meet and confer process with the applicable County labor unions. The meet and confer process is ongoing. Subsequently, SB 627, also known as the “No Secret Police Act”, was signed into law and became effective on January 1, 2026. This law prohibits local, state and federal law enforcement officers in California from wearing facial coverings that conceal their identify, with some exceptions. It further requires law enforcement agencies to create and publicly post written policies related to fiscal coverings by July 1, 2026. Given the implementation of SB 627, an Urgency Ordinance is no longer needed. In November of 2025, the federal government sued the State of California, claiming that SB 627 application to federal law enforcement agents, including ICE agents, is unconstitutional.
• Potential Policy to Prohibit Immigration Enforcement Activities on CountyControlled Properties - On November 4, 2025, the Ad Hoc recommended, and the full Board approved, direction to staff to consider developing a policy prohibiting the use of County-controlled properties for certain specific enforcement activities. Through partnership with County Counsel and in reviewing current policies and protocols, it was determined that a new policy is not needed. The Board direction through the Resolution passed on January 10, 2025, prohibiting the use of County resources and property for immigration activities, provides this direction, and this has been reaffirmed with all County department heads and directors. <https://sonomacounty.legistar.com/LegislationDetail.aspx?ID=7087194&GUID=630532E8-1F20-41A1- 9DF5-331527EAB540>
• Consideration of a Non-Collaboration Ordinance proposed by the Sanctuary Coalition of Sonoma County - The Ad Hoc met several times with the Sanctuary Coalition in order to consider the implementation of a Non-Collaboration Ordinance. The Ad Hoc offered to implement a non-codified ordinance within the jurisdiction of the Board of Supervisors, which could not legally be extended to apply to elected department heads, such as the Sheriff or the District Attorney. This Ordinance would not have resulted in new or changed policy, but rather it would have reaffirmed the state laws already in place and applicable to County operations. Given the lack of support from the Sanctuary Coalition on an effort that would exclude the Sheriff, this initiative was not pursued. The Ad Hoc decided to focus future efforts on exploring initiatives for direct community impact.
• Inventory of Local Immigrant Services - The Ad Hoc will be convening a meeting of local service providers who operate in the immigrant resource space. This facilitated, structured working meeting will be held in February or March. The intention is to inventory current resources and services, identify services gaps and access barriers, and help guide the future focus of the Ad Hoc’s work.
• Funding Local Non-Governmental Organizations (NGOs). City staff also understand that the County has allocated funds to the North Bay Organizing Project to support the North Bay Rapid Response Network and the Secure Families Collaborative, who coordinates with many other NGOs.
Public Comment from the March 10, 2026 City Council Meeting During public comment, members of a committee of Ner Shalom, the local Cotati Synagogue, provided an example ordinance and urged the City Council to adopt the ordinance or one with similar provisions. The following is a detailed summary of the requirements of the proposed ordinance (Exhibit 14):
• Mandating that city employees protect sensitive personal information (which includes race, ethnicity, sexual orientation, and status as a crime victim). City employees may not request or maintain this data unless it is strictly necessary for designated services or authorized in writing and disclosure is prohibited unless required by state or federal statute, a court order, or a valid judicial search warrant. • Prohibiting the use of city funds, property, or personnel for immigration enforcement purposes, including collecting information regarding citizenship or immigration status unless legally required for a city service or litigation. Prohibit cooperation with immigration enforcement operations or requests without a court order, including providing access to non-public city-owned property, such as parking lots, stations, or databases, to immigration authorities. This also would prohibit providing documents in response to an administrative subpoena until it has been vetted by the City Attorney’s Office and the affected individuals are notified.
• Identify city-owned property that could potentially be used as a "staging area" for federal operations and post clear signs stating: “This property... may not be used for immigration enforcement as staging area, processing location, or operation base”. This includes the use of physical barriers, such as locked gates when feasible, to prevent unauthorized access by immigration authorities. The city would also provide free “standardized” signs for private landowners who wish to restrict immigration enforcement on their property • The proposed ordinance also includes several administrative requirements, including developing a plan and training protocols for responding to federal immigration authorities and handling warrants or subpoenas. Designation of a “Immigrant Affairs Liaison” to report federal enforcement activities on city property to the City Council. Within 6 to 12 months of adoption, the City would be required to review their policies for compliance and submit reports to the Council detailing training completion, signage placement, and any requests received from federal authorities for sensitive information. • Furthermore, if the Police Department becomes aware that immigration authorities are present for enforcement, the Chief must notify the Mayor and City Manager, who must then “notify the community”. Signs are also required to be placed in all city lobbies and waiting rooms affirming that citizenship status is not collected or disclosed. • Finally, the Chief of Police must maintain a policy requiring all sworn personnel to visibly display their name or badge number while performing duties, with limited exceptions for undercover work or exigent danger. The proposed ordinance also states that the City Council is to ensure that the Police Department remains locally controlled and is not subject to federal deputization without city consent.
Staff also attempted to locate the requested ordinance by the Sanctuary Coalition of Sonoma County, but was unable to find the ordinance for this item. As mentioned previously, the County of Sonoma appears to have had some type of draft ordinance, but it was no longer pursued by the Sanctuary Coalition once it became clear that it would not apply to the County Sherriff.
Analysis/Discussion
The most likely scenario is that any significant immigration enforcement would not just target the City of Cotati, but more broadly Sonoma County or the North Bay Region. If broad nontargeted immigration sweeps began, local jurisdictions would coordinate with the County Department of Emergency Management through their Emergency Operations Centers to develop operational area awareness and potentially request additional resources. With any County-wide or broader response, regional consistency in public communication and commonality of actions in response will be important to minimize confusion by the local agencies and the public. The County DEM has recently developed an emergency concept of operations (CONOP) for such a scenario, which focuses on post event assistance and recovery according to County staff.
However, at this time, the draft CONOP is not available.
As stated in the joint letter from the Police Chiefs in Sonoma County, our police departments do not cooperate with federal immigration enforcement and are restricted by various state laws, including the Values Act, the Trust Act, and the Truth Act, which prohibits police from assisting or sharing information with federal agencies performing immigration enforcement. This also prohibits police in California from inquiring about the immigration status of anyone they interact with during an arrest. (Exhibit 15)
After reviewing the various actions that other jurisdictions have taken or are contemplating, they generally can be categorized as follows:
• Resolution Urging Action from Congress. Similar to the approach taken by Santa Rosa, a resolution could be developed to urge Congress to require policy actions to restrict certain practices by immigration enforcement officer and improve identification.
This approach does not require significant dedication of City resources, but it does carry some risk of creating adverse impacts to future federal funding. • Limit Immigration Use of Property. While it is clear that the City can limit access to non-public areas (locked facilities such as the Police Station back parking lot and Public Works Corporation Yard, City offices, etc), the ability to limit access to public spaces is legally debatable. In general, the approach taken by other jurisdictions is to post signage prohibiting immigration enforcement staging, processing or other usage. In some cases, the jurisdictions state that they would also provide signage to private properties.
However, no governmental entity can use private property against the wishes of the property owner without property owner permission, so this does not appear to be an effective measure. On public property, the City would be unable to effectively post or restrict use of streets, so this would be limited postings to discreate areas such as parking lots or parks and parking adjacent to City buildings. However, these areas are accessible to the general public, so it’s unclear how immigration agents could be singularly restricted when other objectional groups cannot be. In any case, the stated recourse is to enable the City Attorney to file a civil lawsuit or seek injunctive relief against the Federal Government. This is likely to be expensive and is not expected to be successful in excluding certain members of the public (in this case federal agents).
Another approach, used by the County of Sonoma is a resolution prohibiting the use of County resources and property for immigration activities, which also directs this is reaffirmed with all County department heads and directors. • Restrict Disclosure of Personal Information. The City does not collect personal information, except the police department (via the Public Safety Consortium record system) and some limited information for water and sewer accounts. However, in both cases, this information can only be released by the City to any third party (including the federal government) though a valid court order or as otherwise required by law. • City Protocols for Response. The Police are prohibited by State law from assisting federal immigration enforcement and also have a duty to intercede if our police witness excessive force being used. In significant immigration actions, our Police may be called to keep the peace, particularly if angry crowds begin to gather. However, Chicago and Denver include additional directives, such as attempt to identify the on-scene supervisor and document the actions, if safe to do so, for the purposes of accountability later though referral to the District Attorney or State Attorney General, if they chose to pursue criminal charges. For our small police department, such a policy would be challenging to implement given the regular demands of other concurrent community calls for service.
However, in an event of any significance, this would be the highest priority call to protect public safety and will include our police, who by policy will be recording the incident via body cameras.
• Reporting and Transparency. Berkeley notes that any requests from immigration be documented and reported at the next City Council as an informational item. For transparency, reporting ICE request or known activity in Cotati could happen after the event. The primary consideration is public safety, so information that would encourage crowds of people to converge on an active immigration operation could create a safety hazard for all involved.
• Restricting Use of Masks/Requiring ID. In California, masking and identification of police is already restricted by Government Code §7288 that mandates a policy to ensure transparency in policing. In Cotati, our existing policy mirrors the “No Secret Police” (SB 627) passed by the State of California, but intended to restrict this practice with federal agents. In Cotati, we do not perform undercover work (such as a gang task force, SWAT, etc.), so the only time our officers wear a mask is for medical reasons, such as wearing an N95 mask when working with someone with a contagious illness. • Deputization of Local Police (287g Agreements). As stated earlier, in California, very few, if any, police departments have these types of voluntary agreements for immigration enforcement, as they generally would conflict with state law. Cotati does not have such an agreement and there no way for the federal government to “deputize” a local police officer involuntarily, nor is it legal in California for the police to assist in or perform civil immigration enforcement.
Given the various potential actions taken by other jurisdictions, the following options appear to be the most feasible for consideration by the City Council:
• Develop a resolution urging Congress to require policy actions to restrict certain practices by immigration enforcement officer and improve identification, similar to the City of Santa Rosa. However, as stated earlier, this carries some risk that Cotati is singled out by federal authorities.
• Develop a resolution re-affirming current practices and State law, similar to the City of Petaluma. This is relatively quick to implement and has the benefit of reassuring the public that we do not cooperate with federal civil immigration authorities, and that we follow best practices in policing.
• Developing an emergency CONOP, similar to County DEM, outlining the operational response to a significant enforcement action that is aligned with and complimentary to the County plan once it is released publicly. However, a policy such as this would take more time and staff resources to develop.
• Similar to the County of Sonoma, adopt a resolution prohibiting the use of City resources and property for immigration activities, with direction that this is reaffirmed with all department heads to ensure that the City Council expectations are clearly conveyed to staff. This is relatively quick to implement and has the benefit of reassuring the public that we do not assist federal civil immigration authorities and ensures that all City departments clearly understand the expectations.
Regardless of the actions taken or policies developed, staff recommend close coordination with other agencies in the County that would likely be experiencing immigration actions concurrently.
This is also recommended for clarity of messaging to the public and sharing of resources.
Financial Considerations
Jurisdictions have expressed significant concern regarding retaliation by the Federal Government. The current administration has threatened to withhold or condition federal funds for "sanctuary" jurisdictions (e.g., Executive Order 14,159). The general concern is that these policies could put a "bullseye" on their community and draw increased federal focus.
The proposed actions would likely require 80-160 hours of staff time, but are not expected to have a significant direct financial impact. There is a limited risk that a resolution to Congress may result in some type of retaliation by the Federal Government with future funding.
Environmental Issues
This action does not constitute a project as defined by California Environmental Quality Act.