Back in 2006, I wrote an article for Bender’s Immigration Bulletin, in which I argued that, applying the constitutional doctrine of conflict pre-emption, the INA effectively prevented states from unilaterally enforcing civil immigration law.  The article asserts: “DHS must act as the sole supervisor of alien apprehension and detention. State officers are authorized to assist in carrying out DHS decisions —but only as agents. They are not independent.”  I thought that in wake of the larger-than-life status state immigration enforcement is now taking on, especially in places like Texas and Florida, it might be worth it to take a look again at this little historical snapshot.  Thanks to Dan Kowalski for the permission to repost on this website.