REPORT TO CITY COUNCIL AND STADIUM AUTHORITY BOARD
SUBJECT
Title
Update to City Council on Implementation of City Council Policy 056 - Prohibiting Use of City Properties for Civil Immigration Enforcement Purposes and provide feedback on policy implementation.
Report
BACKGROUND
On February 3, 2026, the Santa Clara City Council unanimously established Council Policy 056, Prohibiting Use of City Properties for Civil Immigration Enforcement Purposes, which prohibits the use of City-owned or City-controlled parking lots, garages, open space, or other facilities as a “Staging Area,” “Processing Location,” or “Operations Base” for civil immigration enforcement purposes. The City Council also approved a statement on behalf of the City of Santa Clara that was shared on the city website and social media handles.
The adoption of Resolution 26-9533 establishing Policy 056 occurred five days prior to the City hosting Super Bowl LX. Due to the limited implementation timeline, certain components of Policy 056 would be implemented prior to the Super Bowl, with a subsequent update on policy implementation to be provided in advance of FIFA World Cup matches. The action taken by Council included the following direction:
(1) Implement Policy 056 immediately (with the understanding, given the short amount of time before Super Bowl LX, and the need to coordinate with Stadium Manager, full implementation of the policy would be limited)
(2) Staff to provide a report at a public meeting prior to FIFA World Cup matches on the implementation of the policy and any recommended changes.
(3) Modify Section B.4 of the City Council Policy to provide training and reporting procedures for City employees.
DISCUSSION
This report presents staff’s implementation update for City Council Policy 056 -- Prohibiting Use of City Properties for Civil Immigration Enforcement Purposes.
(1) Implementation Prior to SBLX:
The following implementation of the policy was completed before Super Bowl LX:
1. Signage (Identify City-owned and City-Controlled properties, Properties with Barriers to Limit Access, and Post Signage)
Ø Staff undertook quick efforts to implement Council Policy 056 across City-owned and controlled properties. This included a detailed review of City-owned and City-controlled properties surrounding Levi’s® Stadium (Stadium), including a review of properties with physical barriers that could be used to limit access to the properties.
The City identified fifteen (15) public facilities and parks as potential Staging Areas, Processing Locations, or Operations Bases. These sites include Agnew Historic Cemetery and Museum, Agnew Park, Fairway Glen Park, Fuller Street Park, Live Oak Park, Meadow Park, Montague Park and Aquatic Center, Youth Soccer Park, Thamien Park, Ulistac Natural Area, Calle de Luna Park, Calle de Mundo Park, Lick Mill Park, and the Northside Branch Library.
In parallel, staff developed an inventory of City-Controlled properties, identifying a total of five sites near the stadium. To ensure awareness and coordination, notification letters were issued to applicable leaseholders on February 6, 2026, outlining the City’s policy requirements. With respect to Levi’s® Stadium, the facility was under lease to the Forty Niners SC Stadium Company (StadCo) during the Super Bowl period and therefore not under direct City control; however, the City provided StadCo with formal notification of the policy.
To reinforce policy compliance, staff also developed standardized signage clearly communicating allowable uses of City-owned properties. Following finalization of the messaging, staff coordinated the fabrication and installation of signage at the fifteen (15) identified City-owned sites located north of Highway 101, completing installation prior to February 8, 2026.
Since February 9, 2026, the City has installed signage at all City parks, the Santa Clara Convention Center, the Yellow Lot Parking structure, and is working with the Stadium Manager to have signage installed before the FIFA World Cup matches at the Stadium. Signage at parking lots (not associated with a park or library) or other city facilities that are public-facing will be posted before June 13, 2026.
2. City Employee Procedure Policy and Training
Ø The City has developed a City Manager’s Directive (CMD) and is currently coordinating with the City Attorney’s Office to finalize the directive. Portions of the CMD are modeled after San Jose’s Safe Site protocols. The CMD establishes procedures for staff related to the implementation of the policy and guidance for responding to contact from immigration agent(s). It defines the roles and responsibilities of staff and supervisors, including incident reporting protocols.
The directive is intended to ensure staff are informed, equipped to respond appropriately to potential policy violations, and maintain employee and resident safety. The CMD also clarifies that while staff may verbally object to the use of City property for immigration enforcement activities, they are not to physically intervene with or obstruct immigration agent(s). Additionally, the CMD reaffirms that the Policy does not prohibit the City from complying with valid federal warrants, subpoenas, or court orders.
The CMD outlines that employees should limit interactions with immigration agent(s). Should a city employee observe or suspect use of city properties for immigration enforcement, the employee is instructed to inform their supervisor, the Person In Charge at the facility/site.
Supervisors are provided with protocols on how to interact with immigration agent(s), guidance on what to ask for, and what types of documentation allow for entry into Employee Only areas. Supervisors are required to submit an Incident Report within 24 hours of the incident. The CMD also includes notification protocols for informing the City Manager’s Office and City Council of confirmed immigration enforcement incidents. Staff has also developed an Incident Report form specific to reporting on Policy 056 violations.
Staff is currently developing a training program for City employees that will cover the protocols and procedures outlined in the CMD. The training will be implemented in two phases. Phase One will prioritize front-line employees who regularly interact with the public at City facilities, with completion targeted by June 13, 2026. Training for all remaining employees will be conducted throughout June 2026.
3. Future Agreements
Ø City Attorney’s office is in the process of developing standardized language that will be included in future leases, licenses, and operation agreements, and amendments to existing agreements, in order to implement Policy 056 on City-owned or controlled properties.
4. Support for Private Property Owners/Businesses and Residents
Ø Signage
The City developed standardized signage that may be voluntarily used by private property owners, businesses, and landowners to communicate enforcement-free zones. This signage was designed to provide clear, consistent messaging.
To ensure accessibility, the signage templates have been made available on the City’s website as part of the policy resource page, “Know Your Rights and Enforcement-Free Zones | City of Santa Clara.” This online resource enables property owners to easily download and display the signage.
Staff have taken additional proactive steps to engage and inform Santa Clara businesses regarding the implementation of Policy 056. Outreach efforts included the distribution of an informational email to local businesses outlining the adopted policy, sharing the City’s dedicated resource webpage, and providing links to relevant local and community resources.
Ø Know Your Rights Materials
The City has developed a dedicated webpage that provides comprehensive information on Council Policy 056, including an overview of the policy, existing laws in California regarding immigration enforcement, guidance on immigrant rights, a direct link to the Santa Clara County office of Immigration Relations website and a Frequently Asked Questions about the policy. This centralized platform is intended to improve public access to accurate information and support community awareness.
To further enhance outreach, the City has distributed “Know Your Rights” Red Cards at all public-facing City facilities, ensuring that residents have readily available, easy-to-understand information regarding their rights.
Ø Additional Efforts:
The City is also working with the Immigrant Protect and Empowerment Network (IPEN) to bring resources to local businesses. IPEN works with its partner, Working Partnerships USA, which provides an Employer Engagement program, hosting in-person training sessions for business owners and sharing resources and information on how to prepare for immigration raids and federal agents visiting the workplace. The City is collaborating with the Silicon Valley Chamber of Commerce to host an Employer Engagement session in June prior to FIFA World Cup.
(2) Provide a report at a Public Meeting
a. This report and the presentation at the May 19 meeting is intended to stratify the City Council request to provide a summary report in implementation of Policy 056. Staff does not recommend any changes to the policy at this time.
Additionally, as the Santa Clara Police Department is the lead agency managing public safety efforts for the Super Bowl, the Department provided the following feedback regarding the impacts of implementing Policy 056 during Super Bowl LX:
The Police Department does not engage in civil immigration enforcement, consistent with state law (including the California Values Act) and long-standing departmental practice.
Policy 056 did not result in any substantive change to police operations during the Super Bowl.
The timing of the policy’s adoption, immediately prior to a major global event, introduced additional complexity in public messaging and contributed to heightened public concern and protest activity, which required adjustments to our crowd management posture.
b. Information regarding data sharing policies
Ø As a SEAR 1 (Special Event Assessment Rating) event, as designated by the US Department of Homeland Security, federal interagency support was integral to public safety operations for Super Bowl LX (SBLX), an event of national/international importance. Collaboration and information sharing were limited to coordinated public safety efforts and criminal threat prevention. This included joint planning, real-time situational awareness, resource deployment strategies and staffing, and unified incident response protocols to ensure a safe and secure environment for the public. The interagency support was effective and efficient in achieving our public safety mission.
As noted below, the Police Department does not engage in civil immigration enforcement. No such enforcement occurred at SBLX, nor at related SBLX operations.
c. Opportunities for updates or refinements to City Council Policy 056
Ø The City is currently implementing Policy 056 and collaborating with IPEN to ensure alignment with current best practices and approaches that best serve the needs of Santa Clara. Through this partnership, staff will continue to evaluate opportunities to refine and enhance the City’s policy framework. IPEN has expressed support for Santa Clara’s adoption of the policy and has indicated that the City’s website is being used as a reference for other jurisdictions.
(3) Modify Section of B.4 of the City Council Policy to provide training and reporting procedures for City employees
Ø No modifications to Section of B.4 of the City Council Policy are recommended. Training and reporting procedures for City employees will be outlined in the draft City Manager’s Directive (CMD), which will be finalized prior to June 13 and modified as needed in the future.
The following are the remaining portions of the policy that need to be implemented:
• Finalize posting of signage before June 13, 2026, at City parking lots.
• Finalize the City Manager’s Directive (Employee policy implementation procedure and training).
• Finalize and deliver training for City employees.
• Coordinate with IPEN and Silicon Valley Chamber of Commerce & Innovation for an Employee Training/Engagement session in Santa Clara.
In addition, the City has executed a Memorandum of Understanding with Silicon Valley Office of Protocol and is currently working with them in anticipation of the upcoming FIFA World Cup. The City has met with representatives from several countries and addressed their concerns about the safety of their citizens. The Silicon Valley Office of Protocol is evaluating the establishment of temporary Embassy services in partnership with countries whose teams are playing matches at the Stadium. The goal is to provide a centralized access point for individuals seeking support or services from their country’s diplomatic representatives.
FISCAL IMPACT
Implementation of the policy has fiscal impacts, including the cost to fabricate and post the signage at City-owned and City-controlled properties. Additional costs include administrative costs for staff time to develop the CMD, develop training, and provide training.
COORDINATION
This report was coordinated between the City Manager’s Office and the City Attorney’s Office.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov or at the public information desk at any City of Santa Clara public library.
RECOMMENDATION
Recommendation
Receive the report and provide input or further direction to staff regarding Policy 056 implementation as Council deems appropriate.
Staff
Reviewed by: Paulina Morales, Assistant City Manager
Approved by: Jovan Grogan, City Manager