When Arizona sheriff Joe Arpaio told a reporter that he would still employ immigration sweeps despite a U.S. court ruling that they unconstitutionally profiled Latinos, U.S. District Court Judge Murray Snow said that Arpaio needed to be trained on how to not base law enforcement decisions on race or ethnicity.

Arpaio boasts that he’s “America’s Toughest Sheriff” but has also been called “the worst in the United States” by Jorge Ramos. In 2007, Mexican tourist Manuel De Jesus Ortega Melendres, along with other plaintiffs and the ACLU, sued Arpaio, arguing that he was profiled in a traffic stop and detained for nine hours. A year later, the Department of Justice began an investigation, concluding in 2011 that Maricopa County Sheriff’s Office had a pervasive bias against Latinos.

In 2013, Judge Snow ruled that Arpaio and his deputies must end racial profiling in traffic stops. The county’s law enforcement agents — including Arpaio — must undergo training to put a stop to racial profiling.