Cases · State immigration-crime laws: Texas S.B. 4 and Iowa S.F. 2340

L.M.L. v. Martin

Western District of Texas · No. 1:26-cv-01170 · Filed May 4, 2026 · Class action

Latest development

Fifth Circuit stayed S.B. 4 injunction pending appeal

The May 29 appellate order stays the preliminary injunction pending appeal. Separately, the June 12 district order stays district proceedings until further order or 30 days after issuance of the appellate mandate; any party may move to lift that litigation stay.

Status as of
June 12, 2026
Docket reviewed through
November 9, 2026

About the case

L.M.L. v. Martin is nationally important because it is the active merits path for Texas S.B. 4 after the en banc Fifth Circuit held that the prior organizational and county plaintiffs lacked standing. The new named plaintiffs are noncitizens directly exposed to S.B. 4's state reentry and removal-order machinery. The Western District of Texas preliminarily enjoined key provisions on May 14, 2026, again finding a likely federal-preemption problem while allowing the separate entry provision to take effect; on May 29, 2026, a Fifth Circuit panel stayed that injunction pending appeal. On June 12, ECF 61 stayed district proceedings pending appeal, subject to further order or expiration 30 days after the appellate mandate.

Relief

The plaintiffs seek classwide declaratory and injunctive relief against S.B. 4 provisions that create a state reentry crime, authorize state removal orders, criminalize noncompliance with those orders, and forbid abatement based on pending federal immigration proceedings.

What's next

Disposition of Fifth Circuit appeal 26-50418, any motion to lift the district litigation stay, and subsequent district proceedings.

New on the docket, not yet reviewed

Nothing new since the last review.

Reviewed events

  1. District court stayed proceedings pending the S.B. 4 appeal

    L.M.L. v. Martin · W.D. Tex. · Source

  2. Fifth Circuit stayed S.B. 4 injunction pending appeal

    L.M.L. v. Martin · W.D. Tex. · Source

  3. Western District of Texas granted preliminary injunction against key S.B. 4 provisions

    L.M.L. v. Martin · W.D. Tex. · Source

  4. Western District of Texas preliminarily enjoined key S.B. 4 provisions

    L.M.L. v. Martin · W.D. Tex. · Source

  5. Noncitizen plaintiffs filed follow-on S.B. 4 class action

    L.M.L. v. Martin · W.D. Tex. · Source

  6. En banc Fifth Circuit vacated prior S.B. 4 injunction on standing grounds

    L.M.L. v. Martin · W.D. Tex. · Source

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