Federal Limits

The Federal Limits Act · model bill

Nine lines,
ready to file.

One model bill, nine modular sections — the same nine limits, written as law. Every clause is adapted from a statute a state already enacted, and where it was challenged, refined by what survived in court. Drop in one section, several, or all nine.

9Modular sections
14Source states
26Source statutes
1Omnibus bill

How it's built ↓

For legislative staff — filing materials

Everything you need to file, in one place.

Everything here is adapted from enacted, court-tested state law, with attribution. Take what your counsel needs.

Download the model bill Editable · .docx Download the one-pager In production See enacted examples Source statutes, by section

The one-pager summary is in production. In the meantime, the printed packet carries the full model text and every source attribution.

State briefs — the one-page case for your state →

What this is

Curation, not drafting.

The Federal Limits Act stitches the strongest enacted provisions from fourteen states into one template — sourced from laws already enacted, defended, and, where challenged, refined in court. The only new drafting is a thin, load-bearing layer: the severability and state-authority clauses, written so the rest stands if any one piece is struck down.

01

Grounded in enacted law

Each section is adapted from enacted state law, with the source statute named in the open — so counsel can trace the substance of every section back to a law that has already been tested.

02

Modular by section

Adopt one section, several, or all nine. The limits are independent levers — a state can take agent ID without touching detention.

03

Written across the spectrum

The case rests on the limits of federal authority — the lawful refusal a state may make — not on party. The conservative case is as strong as the progressive one.

04

One source of truth

The cross-tradition kit a legislator can pick the strongest provision from, section by section, regardless of who first drafted it.

How to use it

Different doors in.

One template, four ways through it.

For legislators

Introduce one section, several, or all

Pick the section your state is missing — the model language is drop-in. Adapt it to your drafting conventions and cite the source statute in committee. For comprehensive reform, introduce the whole Act.

For coalition partners

Show constituents the gaps

Use the catalog's per-state view to show advocates exactly which provisions their state lacks — and hand legislators the specific bill numbers from anchor states they can model.

For media

One movement, one frame

Trust Acts, limited-cooperation laws, data-privacy firewalls, and agent-ID rules are usually covered as separate stories. The Act lets you cover them as one movement against a single standard.

For litigators

Every provision has a precedent

The model language is adapted from enacted statutes that, where challenged, have survived federal review — and each section names the live litigation that tests it.

The bill, section by section

Nine sections.
Nine limits.

Each section answers one of the nine limits. Open any section to read the model language, the statute it's adapted from, and the states that have already enacted it.

01
Section 1 · Resources

No state resources used

Bars the state's own officers, money, equipment, and facilities from federal civil immigration enforcement.

Adapted from

Adapted from California Government Code §7284.6 (SB 54, 2017) and Illinois 5 ILCS 805 (Way Forward Act, 2021). Both statutes have been federally challenged and upheld.

Already law in 16 states + D.C.11 at full strength

At full strength

CACOCTDCILMAMENJNYORWA
SECTION 1. PERSONNEL AND RESOURCE LIMITS.

(a) NO USE OF STATE RESOURCES. -- No state or local agency, and no
officer, employee, or contractor of any state or local agency, shall
use moneys, facilities, property, equipment, supplies, or personnel
to investigate, interrogate, detain, detect, report, or arrest any
person for purposes of federal civil immigration enforcement.

(b) PROHIBITED CONDUCT. -- The conduct prohibited by subsection (a)
includes:
   (1) inquiring into a person's immigration status, country of birth,
       or place of birth, except where required by federal law or for
       a criminal investigation independent of immigration enforcement;
   (2) detaining a person on the basis of a civil immigration
       detainer (ICE Form I-247 or successor form), absent a judicial
       warrant;
   (3) providing personal information to federal civil immigration
       enforcement except as required under section 5 of this Act
       (Information Firewalls);
   (4) participating in federal civil immigration enforcement
       operations, including arrest, transportation, surveillance,
       and detention activities; and
   (5) permitting federal civil immigration enforcement officers
       access to persons in state or local custody for interrogation
       absent a judicial warrant or written consent of the person
       in custody.

(c) APPLICATION. -- This section applies to all state agencies and
all units of local government within the State, including counties,
municipalities, sheriffs' offices, and law enforcement agencies of
every kind.

(d) NO LIMITATION ON COMPLIANCE WITH FEDERAL CRIMINAL LAW. -- Nothing
in this section limits compliance with valid federal criminal warrants,
detainers based on a criminal conviction or pending criminal charges,
or other federal criminal law enforcement activity unrelated to civil
immigration enforcement.

Variations to consider

  • Sworn-vs-civilian distinction: Some statutes cover only sworn law enforcement, exempting civilian state employees in records, motor vehicle, and benefits agencies. Cover all state employees for full credit.
  • Fusion center participation: If your state participates in regional fusion centers (N-DEx, etc.), consider explicit language addressing whether and how state employees may participate.
  • Federal-task-force assignments: Address whether state officers may serve on federal task forces that have civil immigration enforcement components.
02
Section 2 · Contracts

No deputized local police

Bars state and local agencies from entering, renewing, or maintaining any 287(g) agreement — with a 180-day wind-down.

Adapted from

287(g) ban adapted from California Government Code §7284.9 (SB 54, 2017). Termination period adapted from Maryland HB 444 / Ch. 2 (2026, signed Gov. Moore). Detention contract ban adapted from California AB 103 (2017) and New Mexico HB 9 §4 (2026).

Already law in 13 states + D.C.9 at full strength

At full strength

CADEILMDNJNMNYORWA
SECTION 2. COOPERATION CONTRACT PROHIBITIONS.

(a) 287(g) AGREEMENTS PROHIBITED. -- No state or local agency shall
enter into, modify, extend, renew, or maintain any agreement
authorized under section 287(g) of the Immigration and Nationality
Act (8 U.S.C. § 1357(g)), including but not limited to Jail
Enforcement Model (JEM), Warrant Service Officer (WSO), or Task Force
Model (TFM) agreements.

(b) DETENTION CONTRACTS PROHIBITED. -- No state or local agency
shall enter into, modify, extend, renew, or maintain any
intergovernmental service agreement (IGSA) or other contract for
the housing or detention of persons in civil immigration custody,
including but not limited to contracts with U.S. Immigration and
Customs Enforcement, U.S. Customs and Border Protection, the
Department of Homeland Security, or any contractor thereof.

(c) JOINT TASK FORCE AGREEMENTS PROHIBITED. -- No state or local
agency shall enter into, modify, extend, renew, or maintain any
joint task force agreement, memorandum of understanding, or
operational agreement that authorizes federal civil immigration
enforcement to be conducted through the agency.

(d) CONDITIONAL FEDERAL GRANTS. -- No state or local agency shall
accept any federal grant, contract, or other funding that is
conditioned on cooperation with federal civil immigration
enforcement, except where such conditions are required by federal
law and have been judicially upheld against legal challenge.

(e) EXISTING AGREEMENTS. -- All agreements within the scope of
subsections (a) through (c) that are in effect on the effective date
of this Act shall be terminated within 180 days. No new agreements
within the scope of this section may be executed after the effective
date.

(f) ENFORCEMENT. -- Any agreement entered, renewed, or maintained
in violation of this section is void and unenforceable. The
Attorney General shall have authority to seek declaratory and
injunctive relief against any state or local agency violating
this section.

Variations to consider

  • Grandfather clauses: Some early enactments grandfathered existing 287(g) agreements. Avoid this — the methodology codebook §4.2 caps such states at 1/2 score until existing agreements expire.
  • Termination period: Maryland's 180-day termination period (HB 444) is the cleanest. Shorter periods may face administrative challenge; longer periods leave the cooperation pipeline open during transition.
  • Conditional funding subsection: The conditional-funding subsection (d) is novel and may invite federal challenge. Consider including with a severability clause.
03
Section 3 · Sensitive locations

Off-limits: schools, hospitals, courthouses

Bars facilitation at protected places and requires a judge's warrant before entry to their non-public areas.

Adapted from

Sensitive location list adapted from California SB 54 §7284.4 + AB 49 (schools, 2025) + AB 495 (childcare, 2025). Access standard adapted from Connecticut SB 397 (2026). Notification duty adapted from Illinois PA 104-0288 + PA 104-0440.

Already law in 14 states + D.C.8 at full strength

At full strength

CACOCTILMDNJNYOR
SECTION 3. SENSITIVE LOCATION PROTECTIONS.

(a) DEFINITION. -- For purposes of this section, "sensitive location"
means:
   (1) any state or local courthouse, court annex, or court-related
       facility;
   (2) any K-12 school, school facility, or school-sponsored event;
   (3) any hospital, urgent care facility, public health clinic, or
       similar healthcare facility;
   (4) any childcare facility, including daycare centers, Head Start
       programs, and licensed family childcare homes;
   (5) any place of worship, religious institution, or religious
       community gathering; and
   (6) any place of employment within the State.

(b) ACCESS RESTRICTION. -- No federal civil immigration enforcement
officer shall enter the non-public areas of a sensitive location
absent:
   (1) a judicial warrant signed by a federal or state judge or
       magistrate; or
   (2) genuine exigent circumstances posing an immediate threat to
       life or safety; or
   (3) the express written consent of the official responsible for
       the location, provided that any such consent is documented
       and reported under section 7 of this Act (Documentation).

(c) NOTIFICATION DUTY. -- Any state or local employee, school
official, healthcare provider, childcare provider, or place of
worship who becomes aware of federal civil immigration enforcement
activity at or near a sensitive location shall promptly notify the
location's responsible official, who shall document the activity.

(d) NO COOPERATION REQUIRED. -- No employee, official, or volunteer
of a sensitive location shall be required to cooperate with federal
civil immigration enforcement activity that would violate this
section.

(e) CIVIL ACTION. -- Any person aggrieved by a violation of this
section may bring a civil action under section 8 of this Act
(Enforcement and Remedies).

Variations to consider

  • Higher education: Public colleges and universities can be added to the schools category. Maine LD 2106 includes postsecondary; California's protection is K-12 only.
  • 1-mile radius vs. on-premises: Some bills (CA AB 421 pending) propose a 1-mile buffer around sensitive locations. The on-premises standard is more defensible; the buffer adds litigation risk.
  • Domestic violence shelters and homeless shelters: California's SB 841 (2025, failed) would have added these. Worth considering for future expansion.
04
Section 4 · Private detention

Limit for-profit detention

Withholds state permits, funding, and leases from for-profit immigration detention — the lever courts have left standing.

Adapted from

Core prohibition adapted from Illinois 730 ILCS 141 (Private Detention Facility Moratorium Act, 2019) — federal challenge dismissed January 2024. Subsection (b) adapted from Maryland HB 1018 (2026, zoning approval bar). Severability clause designed to preserve the statute against the Supremacy Clause challenge that struck down California AB 32 (9th Cir. en banc 2023).

Already law in 6 statesonly 2 at full strength

At full strength

ILOR
SECTION 4. PRIVATE DETENTION INDUSTRY RESTRICTIONS.

(a) PROHIBITION. -- No private contractor shall own, operate, or
maintain a civil immigration detention facility within the State.
For purposes of this section, "civil immigration detention facility"
means any facility used to detain persons in federal civil
immigration custody, regardless of whether the facility also detains
persons for other purposes.

(b) PROHIBITED ACTIVITIES. -- No state or local government, and no
agency or political subdivision thereof, shall:
   (1) issue any permit, license, or zoning approval for the
       construction, expansion, or operation of a private civil
       immigration detention facility;
   (2) provide any state or local funding, tax incentive, abatement,
       or other financial benefit to a private contractor for the
       operation of a civil immigration detention facility; or
   (3) lease state or local property to a private contractor for use
       as a civil immigration detention facility.

(c) EFFECTIVE DATE FOR EXISTING FACILITIES. -- All private civil
immigration detention facilities operating in the State on the
effective date of this Act shall cease operations within 24 months,
provided that the operator may apply to the Department of [Health
or Corrections] for a one-time extension of up to 12 months for
good cause shown.

(d) SEVERABILITY. -- If any provision of this section is held
invalid as applied to facilities operating under direct federal
contract, the remaining provisions of this section shall remain in
full force and effect as applied to all other private civil
immigration detention facilities and as applied to the activities
prohibited by subsection (b).

(e) ENFORCEMENT. -- Any violation of this section is enforceable
under section 8 of this Act (Enforcement and Remedies).

Variations to consider

  • Direct federal contract carveout: The 9th Circuit struck down California AB 32 as applied to facilities under direct federal contract (Supremacy Clause). The severability clause in subsection (d) preserves the rest of the statute. Litigation is likely; the severability clause has not yet been tested.
  • Zoning vs. operating ban: Subsection (b) is the strongest litigation-resistant approach because it operates through state property and permitting authority — areas the federal government cannot preempt. Pure operating bans face higher Supremacy Clause risk.
  • State-owned facilities operated by private contractors: Define carefully whether "private contractor" includes private operators of state-owned facilities. Most enacted statutes focus on facility ownership; California's targeted both.
05
Section 5 · Information firewall

Protect personal records

Bars handing residents' voter, DMV, school, health, and licensing data to federal civil enforcement without a judge's warrant.

Adapted from

Voter rolls adapted from Colorado SB 24-182. DMV adapted from California Vehicle Code §1801.1 / AB 60 (2013). Schools adapted from California AB 699 + AB 49 + Illinois Way Forward Act. Health adapted from California AB 1184 + AG model policy. Professional licensing adapted from California SB 1159 + B&P Code §135.5 + Illinois IDFPR firewall. ALPR provision adapted from New Mexico SB 40 (2026).

Already law in 16 states + D.C.7 at full strength

At full strength

CACOCTILMDNJOR
SECTION 5. INFORMATION FIREWALLS.

(a) GENERAL PROHIBITION. -- No state agency shall disclose, provide
access to, or transfer any personal information of any person
contained in state databases or records to federal civil immigration
enforcement, except where:
   (1) compelled by a judicial warrant signed by a federal or state
       judge or magistrate;
   (2) compelled by a subpoena issued by a court of competent
       jurisdiction; or
   (3) required by federal law, provided that such requirement has
       been judicially upheld against legal challenge.

(b) PROTECTED DATA DOMAINS. -- The prohibition in subsection (a)
specifically covers the following data domains:

   (1) VOTER REGISTRATION. -- Any state agency that maintains voter
       registration data, including but not limited to voter rolls,
       voter signatures, voter addresses, dates of birth, social
       security numbers, and driver license numbers.

   (2) MOTOR VEHICLE RECORDS. -- Any state agency that maintains
       driver license, identification card, vehicle registration, or
       motor vehicle violation records, including any data contained
       in applications for limited-purpose driver credentials issued
       under [State limited-purpose DL statute].

   (3) SCHOOL RECORDS. -- Any K-12 public school district, charter
       school, or institution of higher education that receives state
       funding shall not disclose student records, attendance data,
       or family contact information beyond what is required by the
       federal Family Educational Rights and Privacy Act (FERPA).

   (4) HEALTH RECORDS. -- Any state-controlled health facility, public
       hospital, county health department, or other state-funded
       healthcare provider shall not disclose patient records or
       presence-of-care information beyond what is required by the
       federal Health Insurance Portability and Accountability Act
       (HIPAA).

   (5) PROFESSIONAL LICENSING. -- The State opts out, to the maximum
       extent permitted by law, of the requirement under section 432
       of the Personal Responsibility and Work Opportunity
       Reconciliation Act (PRWORA, 8 U.S.C. § 1642) to verify
       immigration status through the SAVE database for any
       professional, occupational, or business license issued by a
       State licensing board. State licensing boards are prohibited
       from disclosing applicant data to federal civil immigration
       enforcement except as required by subsection (a).

(c) ALPR DATA. -- The State shall not share automated license plate
reader (ALPR) data with federal civil immigration enforcement or with
any contractor or interstate data-sharing arrangement that includes
federal civil immigration enforcement.

(d) HARD-DENIAL POSTURE. -- State agencies shall actively refuse,
in writing, any federal civil immigration enforcement request
that does not meet the criteria in subsection (a), and shall
maintain a public log of such refusals under section 7
(Documentation).

Variations to consider

  • Professional licensing 2-part test: Per the codebook, this domain requires both a PRWORA opt-out AND an organizational firewall covering boards. CA and IL meet both. NJ and NM are borderline; legal analysis recommended.
  • Hard-denial language: The strongest statutes use "shall not" and "is prohibited from." Soft language ("may decline to") does not satisfy the codebook's hard-denial requirement.
  • State-by-state vs. interstate data networks: If your state participates in N-DEx, NLETS, or fusion centers, the firewall must address whether and how data flows through those networks.
06
Section 6 · Warrant

Require a judge's warrant

Requires a judge's warrant before any state or local actor detains or transfers a person for federal civil enforcement; agency forms don't qualify.

Adapted from

Warrant requirement adapted from California SB 54 §7284.6 + Massachusetts Lunn v. Commonwealth (Mass. SJC 2017) codification approach. No-administrative-detainer exception adapted from Illinois TRUST Act + Connecticut CGS § 54-192h. Rights notification adapted from California AB 263 + Oregon HB 3265. Pre-transfer notification adapted from New Jersey AG Directive 2018-6 / A4071 codification.

Already law in 14 states9 at full strength

At full strength

CACOCTILMAMENJNYOR
SECTION 6. WARRANT REQUIREMENT AND RIGHTS NOTIFICATION.

(a) JUDICIAL WARRANT REQUIRED. -- No state or local agency, and no
officer, employee, or contractor of any state or local agency, shall
detain any person, hold any person beyond the lawful holding period
for state purposes, or transfer any person to federal civil
immigration enforcement custody, absent a judicial warrant signed by
a federal or state judge or magistrate.

(b) NO ADMINISTRATIVE-DETAINER EXCEPTION. -- For purposes of this
section, an administrative immigration detainer (ICE Form I-247 or
successor form), an administrative warrant of arrest (ICE Form I-200
or successor form), or any other document issued by federal civil
immigration enforcement authorities that has not been signed by a
judge or magistrate does not satisfy the judicial warrant
requirement.

(c) RIGHTS NOTIFICATION. -- Whenever a state or local agency makes
any contact with a person regarding federal civil immigration
enforcement, the agency shall provide the person, in a language the
person understands, with notice of the following rights:
   (1) the right to remain silent;
   (2) the right to refuse to consent to a search of person, vehicle,
       or premises;
   (3) the right to refuse to sign any document without speaking to
       an attorney;
   (4) the right to legal counsel; and
   (5) the right to refuse to answer questions about immigration
       status, country of birth, or place of birth.

(d) PRE-TRANSFER NOTIFICATION. -- Before any state or local agency
transfers a person to federal civil immigration enforcement custody
under a judicial warrant, the agency shall:
   (1) provide the person reasonable advance notice of the transfer;
   (2) provide the person reasonable opportunity to contact an
       attorney; and
   (3) document the transfer under section 7 of this Act.

(e) NO LIABILITY FOR NON-COMPLIANCE WITH FEDERAL DETAINERS. -- No
state or local agency, and no officer or employee thereof, shall be
subject to civil or criminal liability under State law for declining
to honor an administrative immigration detainer or for releasing a
person at the conclusion of the lawful holding period for state
purposes.

Variations to consider

  • Massachusetts via Lunn: If your state has a high-court ruling analogous to Lunn v. Commonwealth (Mass. SJC 2017), codification is recommended for stability — court rulings can be revisited; statute is harder to dislodge.
  • "Warrant or detainer" language: Avoid this formulation. Some pre-2018 statutes treated administrative detainers as a substitute for judicial warrants. The 2-point bar requires explicit rejection of administrative detainers.
  • Booking-status language: A statute that prohibits any holding period beyond the lawful state holding period satisfies the warrant requirement element. The detention is either lawful for state purposes or it ends.
07
Section 7 · Transparency

Public cooperation record

Requires public reporting, by statute, on the state's own interactions with federal civil enforcement.

Adapted from

Reporting framework adapted from Illinois 5 ILCS 805/25 (Way Forward Act — annual law-enforcement reporting to the Attorney General on all DHS requests; the gold-standard public report). Scope categories adapted from California SB 54 §7284.10 (annual AG Values Act report) and New Jersey A4071/S3521 / AG documentation framework. Public posting requirement adapted from D.C. Law 26-55. (Note: Colorado SB 21-131 is PII-tracking, scored under STD-05 Information Firewalls, not STD-07.)

Already law in 6 states + D.C.only 3 at full strength

At full strength

CAILNJ
SECTION 7. DOCUMENTATION TRANSPARENCY.

(a) REPORTING REQUIREMENT. -- Each state and local agency that
interacts with federal civil immigration enforcement shall report
quarterly to the [Attorney General / Governor's Office / Department
of State] and shall publicly post the report on the agency's website
no later than 30 days after the end of each calendar quarter.

(b) REPORTING SCOPE. -- Each report under subsection (a) shall
include, at minimum:
   (1) the number and nature of communications with federal civil
       immigration enforcement, including requests for information,
       requests for cooperation, and notifications;
   (2) the number of custody transfers and releases under judicial
       warrant, with the originating jurisdiction and the basis for
       the warrant;
   (3) the number of administrative detainers received, the
       disposition of each, and the agency's response;
   (4) the number of federal civil immigration enforcement officer
       requests to access the agency's premises, facilities, or
       records, and the agency's response;
   (5) the number and nature of contracts, agreements, or
       memoranda of understanding with federal civil immigration
       enforcement entities; and
   (6) the number of state or local employees, by job category,
       trained on the requirements of this Act in the reporting
       period.

(c) STATEWIDE AGGREGATION. -- The Attorney General [or designated
agency] shall publish a statewide annual aggregation of the
quarterly reports, no later than 90 days after the end of each
calendar year.

(d) NON-REPORTING ENFORCEMENT. -- Any agency that fails to file
a quarterly report under this section shall be subject to AG
investigation and may be subject to corrective action under
section 8 (Enforcement and Remedies).

(e) PRIVACY. -- Reports under this section shall not include any
personal information that would identify a specific individual
subject to enforcement, except in aggregate data form. Where
individual data is required for litigation or oversight under
section 8, the data shall be released only under appropriate
protective order.

Variations to consider

  • Cadence: Per revised codebook §4.7, annual reporting with full agency coverage and public posting satisfies the 2-point bar. Quarterly is preferred but not required. The protection is the existence of comprehensive reporting infrastructure.
  • Local agency reach: Statutes that require local agencies to report to a state body, which then publishes aggregated data, satisfy the local-agency element provided enforcement against non-reporting locals exists (subsection d).
  • Transfer-only vs. full scope: Statutes requiring only custody-transfer reporting are too narrow per codebook. Full scope (communications, contracts, premises requests, training) is required for 2/2.
08
Section 8 · Remedies

Hold enforcement accountable

Makes the state's limits enforceable — a private right to sue plus attorney-general authority reaching local law enforcement.

Adapted from

Private right of action adapted from Connecticut HB 7212 (2025) — PRA with compensatory damages and attorney's fees, effective Oct 1, 2025. Minimum statutory damages adapted from Illinois PA 104-0288 ($17K minimum, 3x multiplier). AG authority adapted from Colorado SB 25-276 (civil penalties up to $50,000). Non-retaliation adapted from Oregon HB 3265 enforcement framework.

Already law in 12 states9 at full strength

At full strength

CACOCTILMDNMNYORWA
SECTION 8. ENFORCEMENT AND REMEDIES.

(a) PRIVATE RIGHT OF ACTION. -- Any person aggrieved by a violation
of any provision of this Act, or any organization with standing on
behalf of such persons, may bring a civil action in any court of
competent jurisdiction against the responsible state or local
agency or its employees acting in their official capacity.

(b) AVAILABLE REMEDIES. -- A court adjudicating an action under
subsection (a) may award:
   (1) compensatory damages;
   (2) injunctive relief, including orders compelling compliance
       with this Act;
   (3) declaratory relief;
   (4) reasonable attorney fees and costs; and
   (5) such other relief as the court deems appropriate.

(c) MINIMUM STATUTORY DAMAGES. -- For violations involving the
unlawful detention or transfer of a person under section 6, a
prevailing plaintiff shall be entitled to minimum statutory
damages of $25,000 per violation, in addition to any actual
damages proven.

(d) STATUTORY ATTORNEY GENERAL AUTHORITY. -- The Attorney General
of the State has authority to investigate, audit, and enforce
violations of this Act by any state or local agency. The Attorney
General may:
   (1) issue subpoenas to compel testimony and production of
       documents;
   (2) issue corrective orders requiring an agency to bring its
       practices into compliance;
   (3) bring civil action for declaratory and injunctive relief;
       and
   (4) seek civil penalties of up to $50,000 per violation, payable
       to the State General Fund.

(e) NON-RETALIATION. -- No state or local agency, employee, or
official shall retaliate against any person who reports a violation
of this Act, files a civil action under subsection (a), or
cooperates with an Attorney General investigation under subsection
(d). Any such retaliation is itself a violation of this Act
actionable under subsection (a).

(f) NO LIMITATION ON OTHER REMEDIES. -- Nothing in this section
limits any other remedy available under State or federal law,
including remedies under [State civil rights statutes] and 42
U.S.C. § 1983.

Variations to consider

  • Converse-1983 remedies are addressed separately: See the Companion Section on State Civil Rights Remedies. General state civil rights remedies do not contribute to STD-08 scoring per codebook §4.8 because they are not cooperation-specific.
  • Standing: The PRA in subsection (a) explicitly grants standing to organizations on behalf of affected persons. Some statutes restrict standing to directly affected individuals; broader standing is preferred.
  • Damages floor: Statutes that permit only declaratory or injunctive relief without damages do not satisfy the 2-point bar. Either monetary damages or substantive equitable remedies must be available.
09
Section 9 · Agent identification

Identified agents, recording allowed

Requires the state's own officers to show ID and not mask on duty during cooperation, keeps cameras recording, and protects the public's right to record.

Adapted from

Visible identification + mask prohibition adapted from Oregon HB 4138 (signed April 9, 2026) — the cleanest enacted template, no injunction as of audit date. Civil enforcement mechanism adapted from Connecticut SB 397 (signed May 4, 2026). Severability clause designed to preserve the statute against the Supremacy Clause challenge that enjoined California SB 805 (9th Cir. April 22, 2026). Subsection (f) — state non-cooperation with non-compliant federal operations — is a novel provision designed to operate through state authority and avoid the direct-regulation Supremacy Clause issue.

Already law in 6 states5 at full strength

At full strength

CACTNJNYOR
SECTION 9. FEDERAL AGENT IDENTIFICATION AND RECORDING.

(a) APPLICATION. -- This section applies to all law enforcement
officers operating within the State, including officers of state
and local agencies, federal agencies, and out-of-state agencies
operating under inter-jurisdictional agreement.

(b) VISIBLE IDENTIFICATION REQUIRED. -- Any law enforcement officer
on duty within the State shall visibly display, in a manner
observable by members of the public:
   (1) the officer's name or unique identifying number;
   (2) the agency the officer represents; and
   (3) the officer's badge or other agency-issued identification.

(c) FACIAL COVERING PROHIBITED. -- No law enforcement officer shall
wear a non-medical facial covering that conceals identifying
features while on duty within the State, except:
   (1) personal protective equipment required by occupational health
       standards;
   (2) religious head coverings; or
   (3) facial coverings required by a documented tactical operation,
       provided that the agency files a written justification for
       each such use with the [Department of Justice / Department
       of State Police] within 30 days.

(d) RECORDING. -- Where a state or local law enforcement agency
employs body cameras for state and local officers, those cameras
shall continue to record during any interaction in which the officer
is in the presence of, or directly cooperates with, federal civil
immigration enforcement. State employees and members of the public
have the right to record federal civil immigration enforcement
operations conducted in public spaces.

(e) CIVIL ENFORCEMENT MECHANISM. -- Any person detained, arrested,
or otherwise affected by a law enforcement action conducted in
violation of subsections (b), (c), or (d) may bring a civil action
under section 8 of this Act (Enforcement and Remedies). For
violations of this section involving federal civil immigration
enforcement officers operating in the State, the affected person
may bring action against the State or local agency that authorized,
facilitated, or failed to prevent the violation.

(f) NO STATE COOPERATION WITH NON-COMPLIANT FEDERAL OPERATIONS. --
No state or local agency shall cooperate with, provide resources
to, or facilitate any federal civil immigration enforcement
operation in which federal officers are operating in violation of
the requirements of subsections (b) or (c).

(g) SEVERABILITY. -- If subsection (b), (c), or (d) is held
invalid as applied to federal officers under the Supremacy Clause,
the remaining provisions of this section, and subsection (f) in
particular, shall remain in full force and effect.

Variations to consider

  • Supremacy Clause vulnerability: The 9th Circuit's April 2026 enjoinment of California SB 805 found that visible-ID mandates as applied directly to federal officers violate the Supremacy Clause. The severability clause and subsection (f) are designed to preserve the rest of the statute.
  • "All law enforcement" framing: Statutes framed to apply to "all law enforcement operating in the State" rather than naming federal agents specifically have somewhat better Supremacy Clause prospects but remain at litigation risk.
  • Recording dimension: Body camera mandates that already cover state/local officers satisfy the recording requirement when those officers interact with federal operations. Citizen-recording authorization is the alternative path.
  • Fast-moving: This section is re-evaluated quarterly per codebook §7.3. New York MELT Act is pending Hochul's signature; further enactments are anticipated.

Find your state's gaps

Where does your state stand?

Pick your state — see which of the nine it has drawn, which are still open, and jump straight to the model section that closes each gap.

Companion · beyond the nine standards

A civil-rights remedy that reaches federal officers

A state-law answer to the federal civil-rights statute (42 U.S.C. §1983) — damages, fees, and no qualified-immunity defense — reaching the federal officers the federal statute leaves untouchable.

Adapted from

Vermont H.849 (2026, effective July 1 2026), codified at 12 V.S.A. ch. 205 §5797 — the only enacted civil-rights remedy that explicitly reaches federal officers and offers monetary damages.

State civil-rights-remedy laws enacted in

CAILMAMENJVT
COMPANION SECTION A. STATE CIVIL RIGHTS REMEDIES.

(a) RIGHT OF ACTION. -- Any person whose rights under the
[State] Constitution are deprived by any government official
acting under color of state, federal, or local law may bring a
civil action against the responsible official in any court of
competent jurisdiction.

(b) REMEDIES. -- A prevailing plaintiff under subsection (a)
may recover compensatory damages, punitive damages, injunctive
relief, declaratory relief, reasonable attorney fees, and costs.

(c) NO QUALIFIED IMMUNITY. -- The defense of qualified immunity
under federal law is not available against actions brought under
this section.

(d) LIMITATIONS PERIOD. -- Actions under this section shall be
brought within three years of the alleged violation.

Why it's a companion, not a tenth limit

  • The nine standards measure a state's defensive limits — the walls around its own systems. This is an offensive remedy: a resident, or the state, going to court when an official crosses the line. It rides alongside the nine rather than scoring among them.

Nine sections.
Your legislature can file it this session.

Take the one your state is missing — or the whole Act. The model language is drop-in, and every section already holds somewhere.

See where my state stands →