“Throughout Our History Differences in Race and Color Have Defined Easily Identifiable Groups Which Have at Times Required
Case 5:20-cv-00106 Document 1 Filed on 07/06/20 in TXSD Page 1 of 51 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS LAREDO DIVISION ZAPATA COUNTY, TEXAS, § MELISSA CIGARROA, § CCMD, LLC & GEORGE C. § RINCON, § § CIVIL ACTION NO. _________ Plaintiffs, § § v. § JURY TRIAL DEMANDED § DONALD J. TRUMP, PRESIDENT OF § THE UNITED STATES; CHAD WOLF, as § the Purported Acting Secretary of THE § § UNITED STATES OF AMERICA’S § DEPARTMENT OF HOMELAND § SECURITY and MARK A. MORGAN, as § the Acting Commissioner of THE UNITED § STATES CUSTOMS AND BORDER § PROTECTION, § § Defendants. “Throughout our history differences in race and color have defined easily identifiable groups which have at times required the aid of the courts in securing equal treatment under the laws.” Hernandez v. Texas, 347 U.S. 475 (1954) (argued by Gustavo “Gus” C. Garcia, Laredo’s native son) “When he [Donald J. Trump] landed, he asked, ‘Is it safe for me to get down (off the plane)?’ In his mind, in his own consciousness, he perceived danger[.]”1 City of Laredo Mayor Pete Saenz recalling a conversation with Donald J. Trump, who asked if it was safe to step out of a plane in Laredo, Texas (September 2016). The Fifth Amendment to the US Constitution provides a right to due process, which guarantees equal protection to any person in the United States. Bolling v. Sharpe, 347 U.S. 497, 500 (1954). 1 Tilove Jonathan, Donald Trump persuaded by Laredo mayor to temper border wall plan, Austin American-Stateman, https://www.statesman.com/NEWS/20160904/Donald-Trump-persuaded-by-Laredo-mayor-to-temper-border-wall- plan (Posted Sep 4, 2016).
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