Redwin Tursor
Codex Americana | White Paper | October 9, 2026
Version 1.0 — Documentary review
Executive Summary
The distinction between opposing federal immigration enforcement and holding public officials accountable for unlawful cooperation with that enforcement is substantial.
An elected official can denounce ICE, enact restrictions, authorize an investigation, and sue the federal government without ever imposing a consequence on a state or local official who breaks the rules.
This paper examines that distinction through the public records of eight current state and municipal executives and five additional national political figures.
The principal finding is not that no officer has ever been punished for unlawful cooperation with ICE. It is that the evidence examined here does not establish a qualifying individual sanction attributable to the officials and incidents under review.
That finding is preliminary. It does not establish that sanctions never occurred, that investigations have not been opened, or that all of the conduct examined was unlawful.
It does, however, expose a more important question: whether existing accountability mechanisms are capable of producing individual consequences at all.
Illinois provides the strongest example. Its original TRUST Act established restrictions in 2017. The 2021 Illinois Way Forward Act added investigative authority and reporting obligations. The Attorney General now possesses subpoena powers and authority to pursue judicial relief. The office publishes compliance statistics and has acknowledged communication with a sheriff's office following public allegations of prohibited cooperation.
Yet those mechanisms primarily address institutional compliance. They do not automatically authorize the Attorney General to fire, prosecute, or revoke the certification of individual officers.
That difference matters.
An institution can successfully enforce a law against a prohibited practice without imposing an individual disciplinary sanction.
Conversely, an institution can possess extensive legal restrictions and never meaningfully investigate violations.
A serious accountability audit must distinguish between those outcomes.
1. The Scorecard
| Measure | Documentary finding |
|---|---|
| Political figures examined | 13 |
| Current state or municipal executives | 8 |
| National figures without comparable current executive authority | 5 |
| Jurisdictions with relevant restrictions or policies | Multiple; scope varies significantly |
| Illinois statutory enforcement authority | Verified |
| Illinois annual compliance reporting | Verified |
| Public watchdog request for enforcement | Verified |
| Confirmed official communication following an Illinois complaint | Verified |
| Qualifying individual sanctions established in this review | None established |
| Exhaustive disciplinary-record search | Not completed |
The scorecard deliberately does not classify all jurisdictions as equivalent.
Some have specific statutes prohibiting cooperation. Others rely on executive policies. Some officials permit forms of cooperation that other states prohibit. Denver's mask ordinance regulates a different category of conduct altogether.
A single numerical restriction count would obscure these differences.
Likewise, the absence of a verified sanction in this review must not be interpreted as a nationally established zero.
2. Methodology and Standard of Proof
This is a comparative documentary review, not a comprehensive legal investigation.
The subjects were selected because they are prominent national political figures or current executives whose immigration-enforcement positions make them relevant to questions of future federal leadership and institutional accountability. This is a purposive selection, not a random or exhaustive sample.
The review distinguishes eight current executives—Gavin Newsom, JB Pritzker, Josh Shapiro, Wes Moore, Gretchen Whitmer, Andy Beshear, Maura Healey, and Mike Johnston—from five figures without comparable current state or local executive control: Rahm Emanuel, Pete Buttigieg, Kamala Harris, Cory Booker, and Mark Kelly.
No inference about any person's declaration of candidacy for 2028 is intended.
The evidence examined includes statutes, government guidance, agency reporting resources, official statements, and published investigative journalism.
For an individual consequence to count as verified, this paper requires either an identifiable official record or reporting that identifies a specific official record establishing one of the following:
Termination or removal from employment.
Formal suspension or disciplinary action.
Criminal prosecution for the conduct at issue.
A civil judgment establishing individual liability.
Revocation or suspension of law-enforcement certification.
An allegation, news report of suspected misconduct, political statement, or announced investigation does not itself satisfy that standard.
Nor does the absence of a public record prove that no disciplinary proceeding occurred.
The review does not claim to have searched every personnel file, certification database, court docket, or disciplinary archive. No comprehensive series of public-records requests or interviews with the responsible agencies was completed for this paper.
The resulting negative finding is therefore explicitly provisional.
The paper also makes no determination of criminal guilt concerning individuals discussed in the underlying reporting.
3. The Accountability Ladder
Political discourse frequently collapses five distinct stages into a single concept of accountability.
| Stage | What it establishes | Evidence required |
|---|---|---|
| Denunciation | Political opposition | Public statement |
| Restriction | A binding rule exists | Statute, ordinance, policy |
| Investigation | An alleged violation is examined | Official inquiry or investigative record |
| Referral or enforcement | Findings produce formal action | Referral, lawsuit, administrative proceeding |
| Individual consequence | An identifiable person faces a sanction | Disciplinary record, judgment, prosecution |
The stages are not interchangeable.
A state can move from restriction to institutional enforcement without establishing personal misconduct.
A state can also investigate without substantiating the allegations.
Consequently, the appropriate test is not simply whether a governor has punished someone.
It is whether the accountability system identifies violations, produces defensible findings, and directs those findings to institutions empowered to impose the legally appropriate remedy.
4. Comparative Review of Current Executives
| Executive | Relevant policy or legal framework | Accountability issue | Documentary assessment |
|---|---|---|---|
| Gavin Newsom — California | SB 54, TRUTH Act, and related state protections | Whether prohibited local cooperation produces investigations and sanctions | Extensive legal framework; individual sanction not established here |
| JB Pritzker — Illinois | TRUST Act and Illinois Way Forward Act | Whether documented cooperation triggers statutory oversight | Investigation and reporting mechanisms verified; specific dispositions unresolved |
| Josh Shapiro — Pennsylvania | State Police restrictions with permitted information sharing | Whether administration rhetoric matches continuing cooperation policies | Partial restrictions verified; substantial cooperation remains permitted |
| Wes Moore — Maryland | Restrictions on 287(g) agreements | Whether agencies comply and what follows from violations | Substantial institutional compliance documented |
| Gretchen Whitmer — Michigan | State policy and executive responses to federal enforcement | Need to establish applicable rule and enforcement path | Insufficient evidence for a comparable individual-sanction conclusion |
| Andy Beshear — Kentucky | No equivalent statewide restriction established in this review | Lack of comparable statutory baseline | Not scored against the same restriction standard |
| Maura Healey — Massachusetts | State and local restrictions that vary by agency and jurisdiction | Identification of governing policy and disciplinary authority | No qualifying individual disposition established |
| Mike Johnston — Denver | Municipal cooperation restrictions; federal-agent identification ordinance | Federal conduct versus prohibited local cooperation | Distinct enforcement model; federal preemption challenged |
Table reviewed October 9, 2026. Entries describe the limits of this documentary review, not exhaustive findings concerning every official's conduct.
California: Extensive Rules, Unresolved Individual Outcomes
California has maintained substantial restrictions on state and local participation in federal civil immigration enforcement since the California Values Act, SB 54, and the TRUTH Act.
Its Attorney General has defended the state's authority to restrict cooperation with federal immigration authorities.
The existence of these laws and state-level oversight does not, by itself, establish how many individual officers have been investigated or disciplined.
A complete California accountability audit would require complaint totals, substantiated findings, referrals, litigation results, and disciplinary dispositions associated with the relevant laws.
This review does not establish those totals.
California therefore presents a mature legal framework with an unresolved individual-enforcement record, not evidence that its enforcement institutions have necessarily failed.
Pennsylvania: The Difference Between Restriction and Permission
Pennsylvania illustrates why the actual contents of a policy matter more than a politician's characterization of it.
A February 12, 2026, Spotlight PA investigation reported that Pennsylvania State Police restrictions prohibit various forms of direct immigration enforcement while permitting certain information exchanges with federal authorities.
The reporting identified continuing access to state information systems and circumstances in which state personnel could communicate immigration-related information to ICE.
The Shapiro administration therefore cannot accurately be characterized as maintaining a comprehensive prohibition on cooperation.
It maintains a more limited framework in which some conduct is restricted and other conduct remains permitted.
An accountability audit must first establish which rule applies before asking whether a violation occurred.
Source: Spotlight PA — How agencies under Gov. Josh Shapiro's control do and don't cooperate with ICE.
Maryland: Evidence of Institutional Compliance
Maryland offers an important counterexample to the assumption that restrictions are necessarily symbolic.
Following the state's 2026 prohibition on 287(g) agreements, nine counties were required to end formal participation arrangements with federal immigration authorities.
By May 18, eight counties had withdrawn from their agreements. The ninth reported that its agreement was no longer being enforced.
Those results constitute meaningful evidence of institutional compliance.
They do not, however, establish that individual officers were disciplined for violating the law.
This distinction prevents the audit from penalizing a jurisdiction merely because compliance was achieved without punishment.
The next questions are whether informal cooperation continued, whether any prohibited conduct was substantiated after the law took effect, and what remedies would be available if a sheriff refused to comply.
Source: Maryland Matters — Despite threats, Maryland sheriffs quickly dropped 287(g) agreements.
5. Illinois: Documented Cooperation, Unresolved Accountability
Illinois is the strongest empirical test in this review because it combines documented cooperation, explicit statutory restrictions, an identified enforcement authority, and publicly available compliance reporting.
What the Law Prohibits
The Illinois TRUST Act became law in 2017.
It established restrictions on state and local participation in federal civil immigration enforcement, including certain detention, transfer, information-sharing, and operational-assistance activities.
The rules are not absolute. Criminal investigations, statutory exceptions, and the legal status of particular information exchanges remain relevant.
In August 2021, the Illinois Way Forward Act expanded the state's protections and established additional enforcement and reporting obligations.
This legislative sequence is significant.
The 2017 law created substantive restrictions.
The 2021 amendments supplied stronger machinery for investigating and monitoring compliance.
A political promise became a statutory rule, and the rule subsequently acquired an enforcement structure.
What the Investigations Found
On August 25, 2026, Injustice Watch published two related investigations by Aura Bogado.
The first, produced in partnership with The Intercept, examined cooperation involving Illinois police departments, sheriffs' offices, and prosecutors.
It identified cooperation involving at least 75 agencies across more than one-third of Illinois counties.
The reporting documented interactions that helped route at least 150 people into the federal immigration-enforcement system during the first fifteen months of Donald Trump's second administration.
The second investigation, produced in partnership with WIRED, concentrated specifically on county prosecutors.
Drawing on more than 5,000 pages of records, it reported that prosecutors' offices in approximately one-sixth of Illinois counties shared sensitive information with federal immigration authorities.
This information included addresses, court appearances, case records, and scheduled releases.
These figures are not contradictory.
The broader investigation encompassed police, sheriffs, and prosecutors.
The narrower investigation focused on prosecutors, whose statutory position presents additional legal questions.
The two investigations concern overlapping subject matter but different analytical populations.
Neither report establishes that every documented exchange violated Illinois law.
Some cooperation may have been lawful; other conduct raises questions requiring factual and statutory examination.
Sources:
Injustice Watch and The Intercept — Illinois promised to protect immigrants
Injustice Watch and WIRED — The county prosecutors who became ICE informants
Illinois Has an Identifiable Investigator
Under 5 ILCS 805/30, the Illinois Attorney General possesses authority to investigate violations, obtain information, examine witnesses, issue subpoenas, and seek judicial relief.
That authority was added through the 2021 Illinois Way Forward Act.
The Attorney General may pursue declaratory, injunctive, or other equitable relief when a violation is established.
The legislation also strengthened annual compliance reporting.
Under Section 25, covered law-enforcement agencies must report specified information concerning their interactions with federal immigration authorities.
The Attorney General's office publishes annual Way Forward Act compliance materials, including data concerning immigration detainers, federal immigration requests, and agencies that failed to submit required reports.
The state's website currently provides annual materials for 2022, 2023, and 2024.
This is an important affirmative finding.
Illinois has not merely written prohibitions into law.
It has created reporting requirements, assigned responsibility, collected information, and published compliance data.
Those are operational accountability mechanisms.
Source: Illinois Attorney General — Law Enforcement and Immigration.
The Better Government Association's Earlier Referral
The issue of enforcement did not begin with the August 2026 Injustice Watch reporting.
On October 1, 2025, the Better Government Association publicly called on Illinois Attorney General Kwame Raoul to investigate apparent violations of the TRUST Act.
The organization cited reporting that Adams County Sheriff Tony Grootens had transferred individuals into ICE custody and discussed cooperation with federal immigration authorities.
BGA also cited statements attributed to sheriffs in Gallatin and Pope counties expressing willingness to disregard the TRUST Act under certain circumstances.
Importantly, the Attorney General's office did not simply disappear from the record.
BGA reported that a spokesperson for Raoul's office confirmed communication with Grootens' office but declined to provide additional details.
That establishes a documented institutional response of limited scope.
It does not establish whether a formal investigation was opened, whether a violation was substantiated, whether judicial relief was sought, or whether anyone was disciplined.
The proper finding is therefore more precise than either "the Attorney General did nothing" or "the Attorney General enforced the law."
A public request for investigation occurred. Official communication was acknowledged. The eventual disposition remains unresolved in the evidence examined here.
Source: Better Government Association — October 1, 2025.
The Structural Limit of the Attorney General's Authority
This is the distinction that may matter most.
Section 30 authorizes investigations and civil remedies directed at violations of the TRUST Act.
It does not, by itself, create a universal power to terminate officers, prosecute them criminally, or revoke professional certifications.
Those consequences may depend on separate statutes, employment rules, disciplinary systems, or criminal laws.
An Attorney General could successfully obtain an injunction ending prohibited cooperation without producing a single individual firing.
That could constitute successful statutory enforcement.
It could also leave unanswered whether individual officials knowingly violated their obligations and whether personal consequences were appropriate.
The outcome cannot be determined from the injunction alone.
Consequently, the absence of an individual sanction does not automatically prove the Attorney General failed to use the authority the legislature actually provided.
It may instead expose a mismatch between the statute's available remedies and the type of accountability critics expect.
That is a legislative-design question as much as an enforcement question.
The Prosecutor Problem
The Injustice Watch/WIRED investigation raises a further issue concerning county prosecutors.
Prosecutors have functions and legal responsibilities that differ from those of police officers and sheriffs.
Whether particular employees or offices are covered by specific TRUST Act provisions depends upon the statute's definitions and the relevant conduct.
The interpretation cannot be settled merely by labeling prosecutors as law enforcement.
If their conduct falls outside a statutory prohibition, the question becomes whether that exclusion was deliberate and whether lawmakers intended the resulting limitation.
If their conduct falls within the prohibition, the question becomes whether responsible enforcement authorities investigated.
This review has not established a definitive judicial interpretation resolving every category of prosecutor information sharing identified in the reporting.
That question remains open.
What Remains Unresolved
The available evidence supports several firm conclusions.
Illinois has laws restricting cooperation.
It has a designated investigative authority.
It publishes compliance data.
Journalists have documented conduct that raises serious statutory questions.
A watchdog organization publicly requested enforcement.
The Attorney General's office acknowledged contact concerning at least one earlier allegation.
What remains unestablished is whether these matters produced a completed investigation, substantiated finding, formal referral, judicial remedy, or qualifying individual sanction.
This review cannot establish that no such action occurred.
Nor can it establish that the individuals discussed in the reporting committed crimes.
The next evidentiary step would be to obtain official disposition records, search relevant Illinois court dockets, examine disciplinary proceedings, and ask the Attorney General's office what resulted from the documented referrals and subsequent reporting.
Illinois therefore illustrates three conditions that an accountability audit must distinguish:
A statute without enforcement authority.
A statute with enforcement authority that has not been shown to be used in a particular case.
A statute whose enforcement actions or investigative dispositions are not publicly established.
These are not equivalent forms of institutional failure.
An audit that treats them as interchangeable cannot accurately measure accountability.
6. Denver: Accountability for Federal Conduct
Denver presents a separate model.
In March 2026, the city approved an ordinance restricting law-enforcement officers from concealing their faces during arrests or detentions and requiring identifying information, subject to exceptions.
The ordinance contemplated penalties of up to 300 days in jail and a $999 fine.
On October 8, 2026, the Department of Justice sued Denver, Mayor Mike Johnston, and other city officials, challenging application of the ordinance to federal agents under the Constitution's Supremacy Clause.
That litigation raises a substantial question about a municipality's authority to regulate federal officers performing federal duties.
Denver is notable because it attached specified penalties to a defined rule.
But its ordinance addresses a different accountability gap from this paper's central measure.
It targets identification and conduct by law-enforcement personnel, including federal agents, rather than specifically disciplining local officers for prohibited cooperation with ICE.
Whether any person has been prosecuted under the ordinance was not established in this review.
Its constitutional enforceability is contested.
Denver should therefore be assessed as an attempt to build accountability mechanisms for federal enforcement conduct, not as evidence of individual sanctions for unlawful local cooperation.
Source: Axios Denver — Trump administration sues Denver over ICE mask ban.
7. Political Figures Without Current State Executive Authority
Five additional figures are relevant to national debate but should not be measured against governors and mayors using the same operational standard.
| Figure | Current institutional position relevant to this audit | Appropriate accountability test |
|---|---|---|
| Rahm Emanuel | Former executive official | Proposed institutional reforms |
| Pete Buttigieg | Former federal executive official | Proposed institutional reforms |
| Kamala Harris | Former federal executive official | Proposed institutional reforms |
| Cory Booker | U.S. senator | Legislation and oversight |
| Mark Kelly | U.S. senator | Legislation and oversight |
The distinction is straightforward.
Current governors and mayors may possess direct administrative authority over relevant agencies, although their powers over independently elected sheriffs and local prosecutors may be limited.
Senators possess legislative and oversight powers, not ordinary authority to discipline state police officers.
Former officials can be evaluated by their records and present proposals, but not by disciplinary powers they no longer possess.
This paper does not equate their institutional responsibilities.
Nor does it treat their inclusion as evidence that any has formally entered a future presidential contest.
8. The Next Biden Problem: Restoring Policy Without Repairing Institutions
The deeper question is what happens when national executive power changes hands.
A new administration may condemn the conduct of its predecessor while retaining some of the instruments that made that conduct possible.
That possibility is not merely theoretical.
Title 42 provides a concrete illustration.
The Trump administration used the pandemic-era public-health authority to permit rapid expulsions at the border.
The Biden administration continued operating under Title 42 restrictions for a substantial portion of its first term, notwithstanding major differences in its stated immigration priorities.
The authority finally ended on May 11, 2023, alongside the termination of the relevant COVID-19 public-health emergency.
There were important legal and practical constraints on the administration, including litigation and court orders. The continuation cannot fairly be attributed solely to a discretionary decision to preserve Trump's immigration policies.
Nonetheless, the episode illustrates the problem of inherited executive machinery.
Political transitions do not necessarily produce immediate institutional discontinuity.
Established legal authorities, operational systems, detention infrastructure, administrative habits, and enforcement incentives can persist across administrations.
Sometimes those instruments remain because courts require it.
Sometimes because statutes require it.
Sometimes because dismantling them is administratively difficult.
And sometimes because the incoming administration chooses to preserve them.
Those distinctions matter.
The danger for a future administration is not simply that it might fail to condemn previous abuses.
It is that it might replace political leadership while leaving investigative authority, disciplinary procedures, information systems, and enforcement incentives substantially unchanged.
A policy reversal is not necessarily institutional reform.
A personnel change is not necessarily accountability.
And an administration's public commitment to legality does not establish whether unlawful conduct will be detected or sanctioned.
The appropriate test is whether institutions produce results independent of the political preferences of whoever temporarily controls them.
Source: U.S. Department of State — May 10, 2023, Title 42 transition fact sheet.
9. The Accountability Test
Any jurisdiction claiming to restrict unlawful immigration-enforcement cooperation should be capable of answering five operational questions.
The Rule
What conduct is prohibited, and what exceptions apply?
The Investigator
Which institution has jurisdiction to investigate an alleged violation?
The Referral Path
Where do substantiated findings go, and who decides whether further action is warranted?
The Penalty
What remedies are available against the institution, and what separate sanctions are available against an individual?
The Record
How many complaints, investigations, substantiated violations, referrals, institutional remedies, and individual sanctions have occurred?
Illinois demonstrates why the fourth question must be divided between institutional and individual remedies.
An injunction may stop an unlawful practice without punishing a particular person.
A disciplinary proceeding may punish an officer without changing the defective policy that enabled the misconduct.
Neither outcome alone represents a complete accountability system.
A functioning framework needs the ability to correct institutional conduct, establish individual responsibility when appropriate, and document its decisions.
10. What This Review Does Not Establish
Several material questions remain unresolved.
First, this review does not establish the nationwide number of officers disciplined for prohibited cooperation with federal immigration authorities.
Second, it does not determine whether unpublished or confidential disciplinary proceedings occurred within the jurisdictions examined.
Third, it does not determine how many complaints California, Illinois, Maryland, Massachusetts, or other jurisdictions received concerning such conduct.
Fourth, it does not establish whether the Illinois Attorney General commenced formal proceedings in response to the October 2025 BGA referral or August 2026 reporting.
Fifth, it does not resolve every question concerning how the TRUST Act applies to prosecutors.
Finally, it does not establish that restrictions enacted recently have had sufficient time to produce completed investigations or final sanctions.
These are material limitations, not incidental caveats.
A future audit could resolve them through public-records requests, official interviews, court-docket research, and systematic review of law-enforcement disciplinary databases.
The framework in this paper is intended to make those questions measurable.
11. Conclusion
The central distinction is now clear.
Opposition is not restriction.
Restriction is not investigation.
Investigation is not substantiation.
Substantiation is not automatically referral.
And referral does not necessarily produce an individual consequence.
The evidence examined here establishes that some jurisdictions have enacted meaningful restrictions, some have developed investigative machinery, and at least one—Maryland—has documented substantial institutional compliance with a new prohibition.
Illinois has gone further than a simple statutory declaration. It has given its Attorney General investigative authority, established annual reporting, published compliance information, and acknowledged official communication concerning allegations brought to public attention.
These are genuine institutional features.
But their existence does not answer every accountability question.
The remaining issue is whether violations are identified and resolved through transparent, legally competent processes—and whether individual responsibility can be established and sanctioned where warranted.
That is the distinction the next national administration must confront.
A president can replace agency leadership.
A governor can issue new directives.
A legislature can prohibit cooperation.
None of those actions alone establishes that the government has built a durable system capable of enforcing its own rules.
The most revealing question for any public official is therefore not simply whether unlawful immigration enforcement is condemned.
It is whether the government can identify the rule, demonstrate how violations are investigated, explain the available remedies, and document what happens when misconduct is established.
Until those answers are readily available, America has an immigration-policy debate. It does not yet have a demonstrably complete accountability system.
Sources and Research Notes
Primary legal and governmental materials
Illinois General Assembly — TRUST Act, Section 30, Attorney General enforcement provisions. Primary statutory authority for investigations, subpoenas, and equitable relief.
Illinois Attorney General — Law Enforcement and Immigration. Official guidance, reporting requirements, annual compliance materials, and investigative resources.
Illinois Attorney General — Updated law-enforcement guidance. Explains the 2021 Way Forward Act's expansion of investigative and civil enforcement authority.
U.S. Department of State — May 10, 2023, Title 42 transition. Primary source concerning termination of the pandemic-era authority.
Investigative reporting and independent analysis
Injustice Watch / The Intercept — Illinois promised to protect immigrants. August 25, 2026. Broader investigation across police, sheriffs, and prosecutors.
Injustice Watch / WIRED — The county prosecutors who became ICE informants. August 25, 2026. Prosecutor-specific investigation based on extensive documentary records.
Better Government Association — Call for TRUST Act investigation. October 1, 2025. Documents the public request for investigation and the Attorney General office's limited public response.
Spotlight PA — How Shapiro's agencies cooperate with ICE. February 12, 2026. Documents the distinction between restricted and permitted cooperation.
Maryland Matters — Maryland sheriffs withdraw from 287(g) agreements. May 18, 2026. Evidence of institutional compliance with statutory restrictions.
Axios Denver — Trump administration challenges Denver mask ordinance. October 8, 2026. Documents the city's identification ordinance, specified penalties, and federal constitutional challenge.
Research disclosure: This paper is based on a targeted documentary review completed October 9, 2026. No direct agency interviews, comprehensive disciplinary-record search, or new public-records requests were conducted for this version. Findings concerning the absence of individual sanctions are provisional and should be updated as additional official records become available.
