24 million lawful Mexican alien crossings in a year for Tucson...

Arizona immigration lawsuit: Police officer Martin Escobar vs. Gov. Jan Brewer

17. In the December 2008 publication prepared by the University of Arizona Eller College of Management for the Arizona Office of Tourism, Mexican Visitors to Arizona: Visitor Characteristics and Economic Impacts, 2007-08, it was reported that over 24 million lawful Mexican alien crossings occurred from Mexico to Arizona from July 2007 to June 2008 and that the City of Tucson is a major destination point for Mexican visitors.

18. The City of Tucson is connected to the border cities of Nogales, Sonora Mexico and Nogales Arizona by Interstate 19, an established part the United States Interstate Freeway system; Interstate 19 is a major corridor of travel between citizens of Mexico and United States who utilize this roadway on a 24/7 basis and number in the hundreds of thousands. Additionally, the I-19 corridor is utilized as a significant commercial corridor for international trade and goods in the hundreds of millions of dollars on an annual basis.

19. In plaintiff’s experience as a Law Enforcement Officer, proximity to the Mexican border does not provide any race neutral criteria or basis to suspect or identify who is lawfully in the United States.

20. In plaintiff’s experience as a Law Enforcement Officer, neither the racial and linguistic characteristics of Operations Division South or the Mexican national visitors thereto provide any race neutral criteria or basis to suspect or identify who is lawfully in the United States.

21. During the performance of plaintiff’s duties as a Law Enforcement Officer he has daily contact with numerous Hispanics, a number of whom have a skin color and/or physical features that are commonly attributed to Hispanics; In plaintiff’s experience as a Law Enforcement Officer, skin color and/or physical features does not provide any race neutral criteria or basis to suspect or identify who is lawfully in the United States.