Full Report
Louisiana’s hunting and wildlife authority is one of more than 1,000 state and local agencies that have partnered with US immigration authorities this year alone.
Analysis Summary
# Main Topic
Expansion of US Immigration and Customs Enforcement (ICE) enforcement capabilities through the federal 287(g) program, specifically highlighting the partnership between ICE and the Louisiana Department of Wildlife and Fisheries (LDWF).
## Key Points
- The LDWF signed a Memorandum of Agreement (MOA) with ICE in May, enabling its officers to detain individuals suspected of immigration violations and transfer them to federal custody.
- Since the MOA, at least six men have been transferred to ICE custody after contact with LDWF officers.
- Two of the men transferred were documented as legally present in the US at the time of their detention by immigration authorities.
- The LDWF is one of only three state wildlife agencies (along with Florida and Virginia) to sign a 287(g) MOA this year.
- Partnership expansion is significant, with 1,053 new 287(g) agreements signed this year, representing a 693 percent increase compared to the end of the previous year.
- Documents indicate "joint patrols" involving LDWF, US Coast Guard, and Customs and Border Protection (CBP) resulted in the detention of three individuals in Lake Borgne during an operation ostensibly focused on illegal oyster harvesting, where no direct violations were witnessed, but subjects were detained for immigration issues.
## Threat Actors
- **Primary Agency:** US Immigration and Customs Enforcement (ICE)
- **Partner Agency:** Louisiana Department of Wildlife and Fisheries (LDWF)
- **Facilitating Agencies:** US Coast Guard, Customs and Border Protection (CBP)
- **Motivation:** Enforcement of federal immigration law and expanding the reach of the 287(g) program into state/local level wildlife agencies.
## TTPs
- **Program Utilization:** Operating under the authority of the 287(g) program (Section of the Immigration and Nationality Act).
- **Enforcement Activities:** Investigating, apprehending, detaining, or transporting individuals suspected of violating immigration law.
- **Joint Operations:** Conducting "joint patrols" with federal agencies (Coast Guard/CBP) under the guise of enforcing local statutes (e.g., seed oyster harvesting).
- **Detention:** Transferring individuals directly into federal detention custody without issuing local criminal charges.
## Affected Systems
- **Agencies:** State and local agencies nationally (over 1,200 signed agreements).
- **Specific Entity:** Louisiana Department of Wildlife and Fisheries (LDWF).
- **Victims/Targets:** Individuals encountered by LDWF officers during patrols or stops, including some who had legal status but may have overstayed visas.
## Mitigations
- **Monitoring:** Close scrutiny of MOAs between state/local agencies and ICE to ensure adherence to scope and legal parameters, especially regarding joint operations criteria.
- **Transparency/Oversight:** Requiring clear reporting from participating agencies regarding the nature of encounters and outcomes of transferred individuals (ICE was reportedly unable to confirm status for individuals detailed in the report).
- **Policy Review:** Agencies should review Memoranda of Agreement negotiated under 287(g) to ensure they do not implicitly facilitate cooperation with other federal entities (like CBP) not explicitly named in the initial agreement, as suggested by the Lake Borgne joint patrol.
## Conclusion
The rapid expansion of the 287(g) program is leveraging state-level resources, such as wildlife enforcement agencies, to conduct federal immigration enforcement. This poses a significant risk as enforcement actions appear to target individuals without observed criminal activity and may sweep up legally present non-citizens. Threat intelligence analysts should monitor similar partnerships with environmental, park, or auxiliary state law enforcement bodies, as these present new vectors for immigration enforcement operations outside of traditional policing roles.