Whether a state law requiring federal contractors to pay state minimum wage to federal detainees in a voluntary work program violates intergovernmental immunity or is preempted by federal immigration detention regulations

No question identified. : present oral argument in In re: East Palestine Train Derailment, No. 24-4086 (6th Cir.) (scheduled for argument on October 23, 2025), and in Petersen Energia Inversora, S.A.U. v. Argentine Republic, No. 23-7463 (2d Cir.) (scheduled for argument on October 29, 2025). Mr. Clement also has appellate briefs due in Harris v. City of Los Angeles, No. 25-5029 (9th Cir.) (due on October 20, 2025), Finesse Wireless LLC v. AT&T Mobility LLC, No. 24-1039 (Fed. Cir.) (due on October 24, 2025), and Association of American Universities v. Dep't of Energy, No. 25-1727 (1st Cir.) (due on October 24, 2025). Between now and the current due date of the petition, Mr. Draye will present oral argument in The GEO Group, Inc. v. Menocal, No. 24-758 (scheduled for argument on November 10, 2025). 3. This case presents substantial legal issues surrounding a state law requiring federal contractors to pay the state minimum wage to federal detainees who choose to participate in a voluntary work program that the federal government requires and for which it specifies a stipend of $1 per day. Among those issues are whether the state law is invalid under (i) the intergovernmental immunity doctrine for directly regulating federal operations or for imposing an unequal burden federal operations relative to the State’s own prisons and jails, and (ii) federal preemption under the web of laws regulating immigration detention. 4. Petitioner’s counsel requires the additional requested time fully to research the legal issues and to prepare an appropriate petition for consideration by this Court. 5. Due to this litigation, the federal government has suspended its requirement that GEO offer the voluntary work program. As a result, an extension of time will not prejudice respondents, whose alleged injuries are strictly monetary (in the case of the individual respondents) or relate to the regulation of a program that is suspended (in the case of the State). For the foregoing reasons, petitioner hereby requests that an extension of time to and including December 12, 2025 be granted within which petitioner may file a petition for a writ of certiorari. October 20, 2025 Respectfully submitted, — Paul D. Clement Counsel of Record CLEMENT & MURPHY, PLLC 706 Duke Street Alexandria, VA 22314 (202) 742-8900 Dominic E. Draye GREENBURG TRAURIG LLP 2101 L Street, N.W. Washington, D.C. 20037 (202) 331-3100 drayed@gtlaw.com Counsel for Applicant