some arrestees. In a concurring opinion, Smith maintained that the California law is "materially indistinguishable from the Maryland law" and therefore concluded that "[t]his case is over, and the district court has no obligation to give the Plaintiffs an opportunity to amend their complaint." Judge Charles Breyer in the Northern District of California stayed the case "pending final resolution of state law" in light of the California Court of Appeal's decision in People v. Buza, 231 Cal. App. 4th 1446 (2014), which held the statute unconstitutional on state law grounds. In 2018, the California Supreme Court in People v. Buza, Cal. 5th 658 (2018), reversed the California Court of Appeal's decision, holding that the DNA collection was lawful as part of the normal booking procedure for individuals validly arrested for a serious offense. Smith authored the majority opinion affirming the denial of summary judgment based on qualified immunity, where a deputy sheriff fatally shot a 13-year-old boy. Viewing the facts in the light most favorable to the plaintiffs, the panel concluded that the deputy deployed deadly force within seconds after exiting his vehicle while the boy was walking in the opposite direction on an adjacent sidewalk, holding what appeared to be a gun pointed at the ground, without warning about the amount of force that would be used, and without observing any aggressive behavior by the boy. Because the boy did not pose an immediate threat to law enforcement officials or anyone else, the law clearly established that the deputy's conduct was unconstitutional and the deputy was not entitled to qualified immunity. On June 25, 2018, the U.S. Supreme Court denied cert. Separation of powers and federalism Smith, writing for a unanimous panel, largely upheld a district court's denial of the federal government's motion to enjoin California's sanctuary state laws, including SB 54, the California Values Act. The panel mostly rejected the government's intergovernmental immunity and preemption arguments, concluding instead that the Tenth Amendment's anticommandeering doctrine precluded the government's attempt to force state and local officials to assist with immigration enforcement efforts. The panel concluded, "SB 54 may well frustrate the federal government's immigration enforcement efforts. However, whatever the wisdom of the underlying policy adopted by California, that frustration is permissible, because California has the right, pursuant to the anticommandeering rule, to refrain from assisting with federal efforts." On June 15, 2020, the U.S. Supreme Court denied cert. In re