While much attention has been given to the Trump Administration’s early federal policy objectives to increase immigration enforcement, clients should also be aware of similar increased enforcement policies at the state level.

Last month, Tennessee Governor Bill Lee signed into law a bill passed by the state legislature during a recent special legislative session. The new Tennessee law attempts to strengthen immigration enforcement in Tennessee with the following measures:

1. Creates a Centralized Immigration Enforcement Division at the state level, to be led by a Chief Immigration Enforcement Officer (“CIEO”) appointed by the Governor. The CIEO will coordinate directly with the Trump Administration on federal immigration policies and implementation.
2. Establishes a new driver’s license that distinguishes U.S. citizens from legal permanent residents.
3. As Tennessee law already prohibits sanctuary cities, the law now makes it a felony for local officials to adopt or maintain sanctuary city policies.
4. Through provision of grants, encourages local governments to participate in enforcing federal immigration policies by entering into agreements with federal authorities. The grants may be used for training, operational expenses, investment in law enforcement equipment to be used for enforcement of immigration laws or other activities and programs deemed appropriate by the CIEO. The law also establishes penalties for local officials who do not comply with enforcement mandates.

It is expected that the constitutionality of the new law will be quickly challenged. Consequently, Epstein Becker Green will continue to monitor these developments and provide updates should this happen. The new law took effect February 2025 so clients should be prepared for the implementation of these new measures in the coming weeks. It is also expected that other states may follow suit with similar enforcement measures.