A three-judge panel of the U.S. Court of Appeals for the Ninth Circuit issued an order blocking enforcement of a provision of California’s “No Vigilantes Act” against federal law enforcement agencies and officers.
The law, which was signed by California Governor Gavin Newsom last September, requires any non-uniformed “law enforcement officer operating in California” — a term that explicitly includes federal officers — to “visibly display identification that includes their agency and either a name or badge number or both” while performing enforcement duties. Proponents of the law framed it as a way to “unmask” ICE agents during immigration enforcement operations.
The U.S. Department of Justice filed suit on November 17, 2025, in the U.S. District Court for the Central District of California, challenging the identification requirement (along with provisions of a related law, the No Secret Police Act) as a violation of the Supremacy Clause. In February 2026, U.S. District Judge Christina A. Snyder denied the federal government’s request for a preliminary injunction against Section 10.
She concluded that the United States had not shown the provision would interfere with or take control of federal operations. However, she blocked enforcement of the separate mask-related provisions in the No Secret Police Act, finding they discriminated against federal officers.
In its April 22 opinion, which was written by Circuit Judge Mark J. Bennett and joined by Circuit Judges Jacqueline H. Nguyen and Daniel P. Collins, the panel determined that the United States is likely to succeed on the merits. The court held that Section 10 violates the Supremacy Clause’s intergovernmental immunity doctrine, which bars states from directly regulating the federal government in the performance of its governmental functions.
The opinion stated that the law “attempts to directly regulate the United States in its performance of governmental functions” by mandating how federal officers must identify themselves during operations. It cited precedents including Johnson v. Maryland (1920), which prohibits states from imposing additional qualifications on federal officers, and Mayo v. United States (1943), emphasizing that such regulation controls how the government conducts sovereign activities.
The panel explained that the provision “lays hold of” federal officers “in their specific attempt to obey orders and requires qualifications in addition to those that the [federal] Government has pronounced sufficient.” It applies expressly and exclusively to law enforcement conduct, not to actions ordinary citizens could perform, judges noted.
The court rejected the district court’s focus on the degree of interference, noting that direct regulation of federal operations is impermissible regardless of its scale.
Wednesday’s order enjoins California, Governor Newsom, and Attorney General Rob Bonta from applying or enforcing Section 10 against federal agencies and officers. Enforcement remains paused until the Ninth Circuit resolves the full appeal, a process that could take several months.
