Playbook & Counter-Playbook
176 fights trackedAcross 176 documented county fights, the same moves recur — from the consultants, sheriffs, and federal agencies pushing detention through, and from the communities that stopped them. This page synthesizes both playbooks from the full case record so a community facing a new pitch can recognize what's coming and respond with what has actually worked.
The Attack Playbook — How Detention Gets Built
The model has shifted. The early fights were warehouse purchases and county-led IGSA pitches by consultants like Sabot Consulting. The current record shows a wider repertoire: secret leases through shell companies, unilateral 287(g) signings, state coercion of local officials, and the reactivation of closed prisons that needs no local vote at all.
The dominant 2026 attack. DHS buys or leases buildings — often warehouses at inflated prices — through GSA or Delaware shell LLCs, so localities learn of it only after the deed records, then invoke the Supremacy Clause to claim immunity from local zoning. Tremont PA: a Big Lots warehouse bought for $119.5M (Blue Owl Capital, ~4× assessed) with zero advance notice. Gilroy/Monterey CA: a $26.5M 20-year lease through ECG 6 LLC sat unknown for 16 months. Bexar/San Antonio: a $66.1M warehouse (assessed ~$37M) where the city's own legal staff conceded preemption likely defeats the moratorium.
A sheriff, police chief, or county attorney signs a 287(g) agreement alone — no board vote, often no public notice. This is the single most common cooperation tactic, clustered heavily in Minnesota. Crow Wing Sheriff Klang signed two agreements in March 2025 with no board approval. Pinal County Attorney Brad Miller signed a task-force agreement in June 2025 without telling the Board of Supervisors. Allegheny municipal chiefs signed in apparent violation of the Sunshine Act, with commissioners hearing "nothing about it."
States force cooperation by mandating 287(g) statewide, threatening sanctions, or cutting grants. Tennessee's HB47 requires all 95 sheriffs to enter 287(g) by Jan 1, 2027 or lose funding. Montana AG Knudsen issued a $10,000-per-five-days cease-and-desist to Helena and invoked supervisory control over the Gallatin County Attorney to force ICE data-sharing. Texas AG Paxton sued Houston and Gov. Abbott froze $114M in grants over its ICE ordinance. FL AG Uthmeier threatened to suspend Broward Sheriff Tony.
Operators and sheriffs pitch detention as a budget fix, with per-detainee rates framed as a "creative alternative to raising taxes." Sabot pitched Bradford County FL $239M/yr at 3,000 beds plus 1,250 jobs. Strafford NH earns ~$9M/yr ($150/day) such that exiting would raise property taxes ~20%. Nassau County NY charges $195/detainee/night, the highest in the state. Kenton County KY billed $298,760 in December 2025 alone, at $88/day.
ICE and private operators reopen shuttered prisons under existing IGSAs or sovereign-immunity claims, avoiding any local process or new permit. CoreCivic reopened the former Tallahatchie/California City facility in August 2025 without clear permits. GEO quietly activated the 700-bed McFarland Central Valley Annex in late April 2026, claiming a years-old IGSA to skip California's 180-day notice. CoreCivic's planned 1,600-bed Prairie Correctional reactivation in Appleton MN needed no zoning or purchase at all.
Agencies hide contracts, route records to ICE under federal FOIA, impose confidentiality clauses, or simply miss deadlines. Muscatine County's ICE contract carried a confidentiality clause barring disclosure without ICE approval, and the county attorney referred state records requests to ICE's FOIA process. ICE issued a non-disclosure directive to Florida's 67 sheriffs in spring 2026. Geauga County used a temporal-scoping affidavit to dodge a Marshals contract signed days outside a request window.
ICE runs military-style sweeps and pretextual traffic operations, partnering with state police or using warrants for a handful of targets to detain hundreds by appearance. The La Catedral racetrack raid in Canyon County ID (Oct 19, 2025) used 200+ officers and warrants naming only 5 gambling targets but detained ~400. Nashville's six-night ICE-THP operation ran 600+ traffic stops, marking detainees with numbers in an arrest contest. North Charleston SC troopers stopped "exclusively Latino-appearing drivers." Baldwin County AL raids detained US citizen Leonardo Garcia Venegas — twice.
ICE stations agents at courthouses — sometimes with judicial cooperation sharing target names — and arrests people at scheduled check-ins, chilling access to justice. Allegheny County's President Judge shared target names, birth countries, and court times for 46 planned arrests starting April 21, 2026. ICE made 7+ arrests at Cook County courthouses, including domestic-violence court, in violation of Illinois law. In Providence, agents surveilled a judge's courtroom and detained his high-school intern.
DHS skips environmental review by claiming categorical exclusions, signing same-day NEPA approvals, or routing facilities through state agencies to dodge federal NEPA entirely. Roxbury NJ's $1.7M contract closed Feb 24–25 with same-day NEPA approval and no pre-purchase analysis. Florida built the Everglades "Alligator Alcatraz" with $608M in FEMA funding under state control, and the 11th Circuit ruled (Apr 21, 2026) NEPA didn't apply. The same contractual-vs-operational capacity gap recurs across Roxbury, Maryland, Arizona, and Michigan filings.
ICE and operators bar health and fire inspectors, attorneys, and members of Congress, and run undisclosed detention space to evade court oversight. ICE turned away San Diego County's Public Health Officer at Otay Mesa (Feb 20, 2026). GEO denied Newark fire inspectors at Delaney Hall, which opened with no certificate of occupancy. ICE disclosed a previously secret 9th-floor detention space at 26 Federal Plaza in February 2026 depositions. The Arapahoe DENHOLD hold room processed 1,400+ people — including a 1-year-old — with no IGSA.
Operators escalate bed counts after announcement, move fast to make facilities operational before opposition organizes, and issue contradictory statements to muddy planning. Marana AZ jumped from 513 to 775 beds in two weeks via a sole-source procurement. ICE said it "purchased" the Lebanon TN facility Feb 13, denied it Feb 17, then confirmed "due diligence" Feb 19. Acquisition Logistics LLC — with zero detention experience and unregistered in Texas — won a $1.3B Camp East Montana contract.
What Works — The Counter-Playbook
Of the 176 documented fights, at least 34 have blocked, paused, or forced the abandonment of a detention proposal. The tactics that worked fall into distinct categories — and the two most decisive are recent: 287(g) nullification via a state Attorney General opinion plus a board vote, and state legislation that overrides local cooperation. Communities should identify which tools their situation actually unlocks.
The most decisive new category. A state AG opinion that sheriffs or attorneys lack unilateral authority, weaponized by county boards to void agreements. Minnesota AG Ellison's Dec 12, 2025 opinion became a regional template: Cass County's board declared its agreement "null and void," and Crow Wing residents organized to "join Jackson, Cass & Itasca Counties to nullify the 287(g)." Pinal County's board declared its attorney's agreement illegal, sued him, and won a TRO. Effective across 8+ Minnesota counties and into Arizona.
States enact bans and restrictions that override or preempt local cooperation. Delaware's HB182 (July 2025) bans 287(g) contracts with a 30-day termination window. New Mexico's HB9 Immigrant Safety Act (Feb 2026) bans all new and renewed detention agreements, blocking the Otero and Torrance renewals. Illinois HB5024 bans facilities within 1,500 ft of homes and schools. New York's Local Cops, Local Crimes Act would void all 14 of the state's 287(g) agreements.
Counties and cities pass detention-facility zoning bans, emergency moratoria, and permit revocations before a facility can operate — the preemptive form, which is the only zoning tactic that survives the Supremacy Clause. Baltimore County passed an emergency 6–0 zoning bar (Feb 17, 2026) with retroactive revocation authority back to Jan 1; the trigger was merely a leased attorneys' office. Seven King County WA jurisdictions passed coordinated moratoria after a single DHS pre-solicitation. Howard County MD revoked the Elkridge building permit outright. Greensboro NC required 2,500-ft setbacks that blocked its pitch.
Localities use control of utilities as a hard, non-political veto on mega-facilities. Social Circle GA locked the water meter (Mar 17, 2026) because the 10,000-bed center's 1M-gal/day sewage demand exceeded the city's 660K-gal/day treatment capacity. Tremont PA's facility would need 800,000 gal/day — double the local system, draining the reservoir in a day. Franklin County AR's $825M prison stalled when Fort Smith and Ozark refused to supply water. Byhalia MS opposition argued a town of 1,300 couldn't support 8,500 detainees.
Tribes deploy sovereignty as a hard block federal preemption arguments cannot easily reach. Oglala Sioux President Frank Star Comes Out issued a formal banishment order (Jan 29, 2026) excluding ICE and Border Patrol from Pine Ridge and refused any 287(g), framing arrests as treaty violations. The Choctaw Nation purchased the Durant OK warehouse DHS had targeted, using tribal economic power to remove the property from federal reach. The Mille Lacs Band's Executive Order 2026-01 requires ICE to consult tribal government before entering tribal lands.
Federal preemption means you can't ban the government from buying — but you can make the seller unwilling to sell. Platform Ventures and Port KC severed ties and the developer withdrew from the $80M Kansas City warehouse (Feb 12, 2026). OKC owners confirmed they were "no longer engaged with DHS." Shakopee MN's developer Opus pulled out — "We got it killed." The same pattern terminated deals in Hanover VA and Woodbury MN.
Lawsuits over detention conditions, blocked health inspections, and NEPA violations win injunctions and caps. Maryland AG Brown's NEPA suit won a preliminary injunction (Apr 15, 2026) blocking the Williamsport conversion for failing to take a "hard look" — precedent now cited in Romulus and Bexar. A court capped Baltimore's Fallon Building at 56 detainees with 12-hour medical screening. The California City injunction (Feb 11, 2026) ordered emergency medical care and a court monitor for 1,000+ detainees.
Federal courts release detainees held without bond hearings and enjoin profiling-based stops. West Virginia's Judge Goodwin found mass detentions unconstitutional under the Fifth Amendment, ordering 65 of 71 habeas petitioners released and prompting the jail authority to suspend ICE intake. Hawaii's Rico-Tapia ruling has been cited 200+ times nationally. The Ninth Circuit upheld injunctions barring ICE from using race, accent, or worksite as enforcement factors in Los Angeles.
Board votes to reject, terminate, or oppose contracts, driven by packed meetings and overwhelming testimony. Cumberland County ME voted 3–1 (Apr 22, 2026) to remove ICE from its Marshals contract. Wilson County TN saw 24 of 25 all-Republican commissioners sign opposition, killing the 16,000-bed Lebanon center. Uinta County WY's WyoSayNo packed meetings until CoreCivic withdrew. Nye County NV terminated 5–0 after ICE paid $2M against $8M in costs. But note: in Utah County, 3.5 hours of unanimous opposition testimony still lost the 287(g) vote.
Cities ban ICE from public property and refuse detainers; sheriffs decline 287(g). Boston PD ignored all 57 ICE detainers in 2025 and Mayor Wu banned ICE staging on city property, with five area cities following. Philadelphia passed a seven-bill "ICE Out" package (mostly 16–1) on Apr 23, 2026. Hennepin Sheriff Witt refused new agreements through Operation Metro Surge. Bristol County MA's new sheriff required ICE to file formal records requests, citing an $800K liability settlement.
Forcing disclosure of contracts, billing, and surveillance via records suits and ethics filings. The Iowa Freedom of Information Council sued Muscatine after 10 months of denials, and an ethics complaint forced the county attorney's resignation after an Iowa Supreme Court reprimand. A Kentucky AG opinion ruled Oldham County violated the Open Records Act. Info4PublicUse obtained 313 pages exposing Flock ALPR/ICE data-sharing in southern Oregon.
The single most important variable is timing — winning the race against a fait-accompli purchase by acting on leaked DHS plans within hours. Kansas City's council blocked federal detention permits in an emergency session hours after ICE toured the warehouse (Jan 15, 2026), preventing closure. Marshall County MS held an emergency press conference the day after a leaked DHS document surfaced, with a 20-vehicle rally the next day. ACLU-NH released leaked ICE planning docs and the governor released the full "Detention Reengineering Initiative."
Republican officials opposing facilities in red areas carry outsized weight, sometimes killing projects outright. Sen. Roger Wicker (R-MS) wrote DHS and Secretary Noem agreed to "look elsewhere" on Byhalia. Wilson County's 24-of-25 all-GOP commission and Sen. Blackburn killed Lebanon. Gov. Ayotte (R-NH) and the all-Democratic delegation jointly forced DHS to scrap Merrimack. North Dakota sheriffs forced DHS to delete its false "sanctuary jurisdiction" list within days.
What Doesn't Work — The Limits of Local Power
The record is equally clear about what fails. The recurring lesson: the Supremacy Clause nullifies local action taken after federal acquisition, which is why pre-emptive zoning, infrastructure veto, tribal sovereignty, and sheer speed are the only reliable counters once a federal deal is underway.
Once DHS owns the property, local action is routinely overridden by preemption. Surprise AZ passed a five-year ban post-purchase — unenforceable. San Antonio's own legal staff conceded the Supremacy Clause likely exempts the federally-owned site from the city's 9–2 moratorium. McAllen's mayor said the city's options were limited because federal facilities are immune from local zoning. The lesson: zoning must be pre-emptive, before acquisition.
State laws regulating how federal agents operate fail in court. California's SB 627 anti-masking law was enjoined by the Ninth Circuit (Apr 22, 2026) on Supremacy Clause grounds; its sponsor had to pivot to a state-law-enforcement-only version to cure the defect. Connecticut's similar bill remains only contested.
Opposition that cannot reach the decision lever fails. Strafford County NH's delegation voted 29–4 to reject the budget in protest, but commissioners control the contract, so the ~$9M/yr partnership continued. Utah County's commission approved 287(g) despite 3.5 hours where every commenter opposed. Escondido CA collected 2,000+ signatures and 33 officials' letters, but the council declined to cancel the contract.
Nullification only binds officials who comply. Mille Lacs Sheriff Burton refused to rescind his MOU, saying the AG opinion "does not carry influence with me." Itasca's sheriff said the agreement won't go to the board and "he doesn't need it." These cases stay paused or contested — they require litigation to enforce.
Reversing course to appease a hostile state does not buy relief. Houston gutted its ICE ordinance 13–4 (Apr 22, 2026), yet Gov. Abbott kept the $114M in grants frozen and signaled the state would litigate regardless. Helena rescinded its sanctuary resolution under the Montana AG's $10K-per-five-days threat and still lost.
Where enforcement is already operational, protest rarely reverses outcomes. Franklin County VT's dairy industry and Migrant Justice organized after the Pleasant Valley Farm raid, but 3 of 8 workers were deported via expedited removal. Contrast with courthouse and conditions cases, where litigation — not protest — won releases.
Is your county being pitched?
Check the heat map for signal convergence in your county, read the county fights for detailed case studies, use the FOIA generator to file records requests, and contribute what you find.