Ninth Circuit Blocks California’s No Vigilantes Act ID Requirement for Federal Agents, What the Ruling Means and What to Do

On October 14, 2026, the U.S. Court of Appeals for the Ninth Circuit ruled that California cannot enforce Section 10 of its No Vigilantes Act (S.B. 805), which requires nonuniformed officers to visibly display identification, against federal agencies and officers. The court held that the requirement likely violates the Supremacy Clause because it directly regulates how federal officers perform federal duties. It reversed the lower court’s refusal to block the law and directed the district court to enter a preliminary injunction.

The Limits of the Ruling at a Glance

• It covers one provision. Only Section 10 (California Penal Code § 13654) is affected.
• It protects federal actors only. The injunction runs in favor of the United States, federal agencies and federal officers. It does not stop California from applying ID rules to state and local officers.
• It is preliminary. It is not a final judgment resolving every claim in the case.
• It does not decide the mask law. California’s separate No Secret Police Act (S.B. 627) was already subject to a district court injunction as applied to federal officers, and that issue was not appealed.
• It does not give federal agents blanket secrecy. Federal law and agency policies on identification still exist (see “Know Your Rights” below).
• It does not decide other states’ laws. It may influence similar cases, but each law and record is different.

Quick Facts

Detail	Information
Decision date	October 14, 2026
Court	U.S. Court of Appeals for the Ninth Circuit
Case	United States v. State of California
Appellate case number	26-926
District court case	2:25-cv-10999-CAS-AJR (C.D. Cal.)
Opinion author	Circuit Judge Mark J. Bennett
Other panel judges	Jacqueline H. Nguyen and Daniel P. Collins
California law	S.B. 805, the No Vigilantes Act
Provision blocked	Section 10, California Penal Code § 13654
Constitutional basis	Supremacy Clause and intergovernmental immunity
Result	Denial of preliminary injunction reversed; district court told to enter one
Not decided	The entire act, other California immigration laws, the mask law
Court documents	See the Official Sources section at the end of this article

What Did the Ninth Circuit Block?

Section 10 requires covered nonuniformed officers, including federal officers, to visibly display identification showing their agency and either their name or badge number during specified enforcement duties, such as arrests, detentions and crowd control. It contains exceptions for certain undercover work, tactical operations, emergencies, protective equipment that prevents display and some protective details. A knowing and willful violation is a misdemeanor.

The court instructed the district court to bar California, Governor Gavin Newsom and Attorney General Rob Bonta from applying or enforcing Section 10 against the United States, federal agencies and federal officers.

Why the Court Relied on the Supremacy Clause

The Supremacy Clause (U.S. Const. art. VI, cl. 2) makes federal law supreme over conflicting state law. Under the related doctrine of intergovernmental immunity, a state generally cannot directly regulate the federal government’s operations, or discriminate against the federal government, without congressional authorization.

The panel reasoned that Section 10 is aimed specifically at law enforcement officers performing law enforcement operations. In the court’s view, it regulates the manner and conditions under which federal agents enforce federal law, and Congress had not authorized California to do that.

The court rejected the argument that individual officers could simply raise a Supremacy Clause defense if prosecuted. It treated the federal government’s right not to be directly regulated as a separate problem from any single officer’s defense. The state’s exceptions and safe-harbor provisions did not change that result.

The principle does not make every state law that touches federal employees invalid. A generally applicable rule that affects federal officers only incidentally is treated differently from a rule that directly controls federal governmental conduct.

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• Trump DOJ Sues Denver Over ICE Mask Ban, What The Law Says
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Laws and Cases Behind the Decision

Authority	Why it matters
U.S. Const. art. VI, cl. 2 (Supremacy Clause)	Source of federal supremacy over state law
Intergovernmental immunity doctrine	Limits direct state regulation of, and discrimination against, the federal government. Key cases include McCulloch v. Maryland (1819), Johnson v. Maryland (1920), Mayo v. United States (1943), North Dakota v. United States (1990) and United States v. Washington (2022)
In re Neagle, 135 U.S. 1 (1890)	Classic case on Supremacy Clause immunity for federal officers acting within their authority
California Penal Code § 13654	The blocked ID requirement
California Penal Code § 13653	Lets an officer request identification from someone claiming to be an officer in specified circumstances; not decided here
California Government Code § 7288	Requires agency identification policies; the district court found the U.S. lacked standing to challenge it and the U.S. did not appeal
California Penal Code § 185.5 (S.B. 627)	The separate facial-covering restriction, already enjoined as to federal officers by the district court
Winter v. NRDC, 555 U.S. 7 (2008)	The four-part test for preliminary injunctions
28 U.S.C. § 1292(a)(1)	Allows appeal of orders refusing preliminary injunctions
8 U.S.C. §§ 1103 and 1357	Federal statutes defining immigration officers’ enforcement powers
8 C.F.R. § 287.8(c)(2)(iii)	Federal regulation requiring an immigration officer making an arrest to identify themselves as an immigration officer and state the reason for arrest as soon as practical and safe
18 U.S.C. § 912 and Cal. Penal Code § 538d	Federal and California laws against impersonating officers

How the Case Got Here

Date	Event
September 20, 2025	California enacts the No Vigilantes Act (S.B. 805) and the No Secret Police Act (S.B. 627)
November 17, 2025	The United States sues California, Newsom and Bonta
February 2026	District Judge Christina Snyder blocks the mask restriction as applied to federal officers (it discriminated against the federal government by exempting some state officers) but declines to block Section 10
February 19, 2026	Ninth Circuit enters a temporary administrative injunction against Section 10 as to federal officers
April 22, 2026	Ninth Circuit grants an injunction pending appeal
October 14, 2026	Ninth Circuit issues a published opinion reversing the denial and directing a preliminary injunction

The federal government appealed only the denial of relief on Section 10. The mask-law ruling and the standing rulings on the agency-policy provisions were not part of the October 14 appeal.

What the Mask Law Status Means

The district court’s earlier injunction against the No Secret Police Act’s face-covering prohibition, as applied to federal officers, was based on discrimination: the rule exempted some state officers while covering federal ones. That is a different legal theory from the direct-regulation reasoning the Ninth Circuit used for Section 10. The October 14 ruling neither newly granted nor lifted the mask injunction.

Is This Final?

No. A preliminary injunction preserves the situation while the case continues, and the district court must now enter it. California may seek rehearing en banc before the full Ninth Circuit or review by the U.S. Supreme Court, and the underlying case may continue on other issues. The panel’s reasoning is strong, but a final outcome depends on later proceedings.

What This Means for You: Reader Action Guide

If you live in California or may encounter federal agents

• Know what the ruling does. California cannot use § 13654 to require covered federal officers to display a name or badge number. You may still ask who they are.
• Ask calmly. You can ask for the officer’s name, agency and badge number, and the reason for any stop or arrest. Federal regulations require an immigration officer making an arrest to identify themselves and state the reason as soon as practical and safe (8 C.F.R. § 287.8(c)(2)(iii)).
• Do not physically resist or flee, even if you believe the stop is unlawful. Challenge it afterward through a lawyer.
• Remember your constitutional rights. You generally have the right to remain silent and may decline to consent to a search of your person, car or home. Entry into a home generally requires a judicial warrant or valid consent, and an administrative immigration warrant is not the same as a judicial one.
• Document the encounter. Write down the date, time, place, agency markings, vehicle details, any names or badge numbers and witnesses. Video recording of officers in public is generally lawful, but do not interfere with the officers.
• Contact a lawyer or a trusted legal-aid or immigrant-rights organization if you or someone you know is detained.

If you suspect impersonation

Do not confront the person. Move to a safe place and call 911. Impersonating a federal officer is a federal crime (18 U.S.C. § 912), and impersonating a peace officer is a crime under California Penal Code § 538d. You can also report it to the FBI.

If you want to file a complaint about federal officer conduct

Complaints can be directed to the DHS Office for Civil Rights and Civil Liberties, the DHS Office of Inspector General and the agency’s internal affairs office. Claims for injuries or property damage by federal employees may fall under the Federal Tort Claims Act (28 U.S.C. §§ 1346(b) and 2671 et seq.), which has strict deadlines and administrative steps. Suits for constitutional violations by federal officers are limited by Supreme Court precedent, so talk to an attorney promptly.

If you work in state or local law enforcement

California agencies cannot enforce § 13654 against covered federal officers while the injunction is in effect. Other California identification rules for state and local officers are not affected by the injunction. Check your agency’s counsel for guidance.

If you are an attorney, advocate or journalist

Read the full opinion and docket, track the district court’s injunction order, and watch for any petition for rehearing en banc. Do not describe the ruling as striking down the entire act or as permanent.

If you follow similar laws in other states or cities

This ruling may be cited in other cases, but it does not automatically invalidate other laws. See the Denver mask-ban litigation, which is a separate case.

What Happens Next?

1. The district court enters the preliminary injunction as directed.
2. California may seek rehearing en banc or Supreme Court review.
3. The underlying case may continue on remaining issues, toward a final judgment.
4. Other courts may consider similar state or local laws, with results that depend on each law’s wording and record.

Frequently Asked Questions

What did the Ninth Circuit block?

Section 10 of the No Vigilantes Act, which requires covered nonuniformed officers to visibly display identification, as applied to federal agencies and officers.

Did the court strike down the whole law?

No. It addressed Section 10 only, as applied to the federal government.

Can California still require state and local officers to display ID?

The injunction is aimed at enforcement against federal actors. It does not generally stop California from applying the statute to state and local officers.

Did the Ninth Circuit rule on California’s mask ban?

No. The district court had separately enjoined the mask restriction as applied to federal officers, and that was not part of this appeal.

Why did the court rely on the Supremacy Clause?

It found the law directly regulates how federal officers perform federal duties without congressional authorization.

Can federal agents always hide their identity now?

No. The ruling limits enforcement of one California statute. Federal regulations and agency policies on identification still apply, and other legal questions about officer conduct are not decided.

Is the ruling final?

No. It directs a preliminary injunction. Rehearing, Supreme Court review and further district court proceedings are possible.

Does this affect other states’ laws?

It may influence them, but it does not automatically invalidate similar laws elsewhere.

What should I do if someone claims to be a federal agent?

Stay calm, ask for their name, agency and credentials, do not resist, document the encounter and contact a lawyer. If you suspect impersonation, move to safety and call 911.

Official Sources

• Ninth Circuit, United States v. California, No. 26-926 (October 14, 2026): https://cdn.ca9.uscourts.gov/datastore/opinions/2026/10/14/26-926.pdf
• Ninth Circuit, April 22, 2026 opinion granting an injunction pending appeal: https://law.justia.com/cases/federal/appellate-courts/ca9/26-926/26-926-2026-04-22.html
• Central District of California docket, No. 2:25-cv-10999-CAS-AJR: https://dockets.justia.com/docket/california/cacdce/2%3A2025cv10999/995805
• California Penal Code § 13654: https://law.justia.com/codes/california/code-pen/part-4/title-4-7/section-13654/
• California S.B. 627, No Secret Police Act: https://www.leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB627
• California Attorney General statement: https://oag.ca.gov/news/press-releases/attorney-general-bonta-transparency-and-accountability-are-foundation-good-law
• Governor Newsom, September 20, 2025 announcement: https://www.gov.ca.gov/2025/09/20/governor-newsom-signs-laws-to-protect-school-children-and-hospital-patients-and-limit-fear-tactics-used-by-trumps-secret-police-force/

AllAboutLawyer.com provides general legal information, not legal advice, and is not a law firm. This article summarizes a federal appellate ruling issued October 14, 2026. The injunction concerns one California statute and its enforcement against federal agencies and officers. Later rulings, rehearing or Supreme Court review may change the legal position. Statutory and case citations are for general orientation; verify them against official sources. If you or someone you know is facing an immigration enforcement encounter, consult a licensed attorney.