ICE has temporary holding rooms in New York City at 26 Federal Plaza, a federal office building. The location is intended for brief custody, generally 12 hours or less, while people are processed or transferred to a detention facility. The rooms have no beds, cots, showers, or windows.

In Sergio Alberto Barco Mercado v. Markwayne Mullin, et al., Judge Lewis A. Kaplan of the United States District Court for the Southern District of New York ruled on September 24 that even after temporary orders improved conditions, ICE exceeded room capacities, failed to provide confidential legal calls and used other floors to hold detainees contrary to the court’s orders.

Page 108 of the opinion:

“The conditions of confinement to which ICE subjected immigration detainees at 26 Fed during the summer of 2025 were inhumane and unconstitutional. By detaining far more persons in the hold rooms than ever was intended and for far longer than ever was intended, ICE objectively deprived detainees of sleep, sanitary living conditions, basic personal hygiene needs, sufficient food and water, and adequate medical care. ICE prevented detainees from accessing counsel, who might have stood in the way of what it was doing. Some of these deprivations impacted detainees immediately; others only after longer periods. ICE knew, or should have known, that how it was treating detainees was wrong, yet it continued to do it anyway. It did so to inflict punishment on detainees and induce them to self-deport. The [Temporary Restraining Order] and [Preliminary Injuction of Sept 17, 2025] abated ICE’s constitutional violations, but ICE’s ongoing noncompliance and the cognizable danger that it, amid rising immigration arrests, again will use 26 Fed as the “give” in the system prove that a permanent fix is needed to protect the Constitution against the administration’s mass deportation program.”

A Washington Post-participated investigation report says that the Trump administration pledged at least $410 million to secure third-country deportation arrangements with 31 countries, mostly in Africa and Latin America. A State Department Office of Remigration, led by Christian Ehrhardt, runs the program. More than 25,000 people have been sent to at least 28 third countries.  Nominally the program is for deportations of persons whose home countries refuse to accept. Most of the deportations have been to Latin American countries, many Mexico.  Costa Rica accepted migrants from China, Russia, Iran, and Afghanistan.

The African countries which are or are currently negotiating to accept deportations are Democratic Republic of the Congo, Equatorial Guinea, Eswatini, South Sudan, Central African Republic, Ghana, Sierra Leone, Uganda, Togo, Guinea-Bissau, and Gabon. One instance: Liberia received a deportation flight, but the six migrants refused to leave the aircraft and were rerouted to Equatorial Guinea.

The reporting team assembled the 25,000 figure from estimates, including few specific data sources (for instance, Human Rights Watch counted 12,977 third-country nationals sent to Mexico between January 2025 and March 2026).

The article mentions without going into much depth of detail how third party deportations to Africa are designed to frighten unauthorized persons into their self-deporting to their home country. The Abrego Garcia case (covered in other posts): His lawyers allege that prosecutors offered him a guilty plea followed by deportation to comparatively safer, Spanish-speaking Costa Rica, while threatening deportation to Uganda if he refused.

How the story was sourced.” The Washington Post writes it is part of a project involving  “72 journalists, 26 news organizations, 15 countries: a global investigation into the Trump administration’s secret deals to expel people worldwide.”

The Migration Policy Institute in January 2026 published a study of “externalization,” which puts the administration’s third-party deportation policy in global context. Europe and Australia have externalization policies as well was the U.S. they include:

Preventing migrants from reaching destination countries, for example, EU cooperation with Libya and Tunisia and U.S. cooperation with Mexico.

Return hubs. Rejected asylum seekers are transferred to facilities in third countries while authorities arrange return, settlement or further movement. The EU authorized this approach in 2026.

External legal-pathway screening. The Biden administration’s Safe Mobility Offices in Latin America was this approach –killed by the Trump administration.

This posting follows up with September 14 developments on Trump’s campaign on illegal voters. In sum, the administration is surrepiciously implementing its real plan. Unburdened by evidence of non-voting eligible people on voting rolls of more than a few hundred in a state, the Trump administration continues to work this issue.

Yesterday, in United States Postal Service v California, the Supreme Court 7-2 dealt a death blow to what I call the Postal Service plan for this November, without a majority opinion but with one concurring and two dissenting (Alioto and Thomas) opinions. The apparent rationale is that to apply the plan would at this time impose an intolerable burden on state and local officials. This leaves what I call the Postal Serbice  plan basically viable for 2028.

The administration’s legal argument comes to this: State and local election systems can set their own rules but do not have the authority to set rules for how the Postal Service oversees the delivery of mail – by content, envelop design, address management, etc. the Postal Service has been granted wide discretion. Were there no last-minute controversy, the case (again, United States Postal Service v California) might have swung in favor of the administration.

In my recent post, ”Trump’s real plan to control state and local voting,”  I lay out what I think is the real administration’s strategy, which is to apply its own databases against state voter lists and to reject matches that appear to show a non-citizen on a voter list. I noted the quality control and other issues involved.

Alabama has undertaken to so this voluntarily, resulting in 184 findings out of a population of three million.

On the same day (Sept 14) of the Supreme Court decision, Senator Alex Padill, and Senate Democratic Leader Chuck Schumer (D-N.Y.) announced the receipt of a new whistleblower disclosure they received on September 8. The whistleblower disclosed that over the past month or so DHS and USCIS have been inspecting state voting list directly, using their own staffs and applying undisclosed methods.   This is an effort to apply the administration’s strategy presumably to come up with hair-raising accounts of how a Syrian suicide bomber has voted repeatedly.

DHS launched an “Unlawful Voter Initiative” in August 2026 to look for noncitizens who had registered or voted. It assigned hundreds of employees from U.S. Citizenship and Immigration Services’ Fraud Detection and National Security Directorate to the effort. On August 21, they were told to watch a training video lasting about an hour and 45 minutes. By August 25, they were reviewing names supplied by DHS. The stated target was 40 cases per employee per day, or roughly 12 minutes per person, with the rushed review to be completed by September 12.

DHS supplied data suggesting that particular people might be unlawful voters. Some of that data reportedly came from its SAVE immigration-status system (see my prior post.)

Officers then compared federal data about a person’s citizenship and immigration history with state voter records. To retrieve individual records from state websites, they (per the whistleblower) entered identifying details such as birth dates or partial Social Security numbers and, where required, claimed to be the voter or to have the voter’s permission. The whistleblower says those claims were false and may have violated state laws governing access to voter information.

Officers were then instructed to create a record in the federal “TEC” law enforcement database, a shared repository for suspected persons. These records were to be identified as “unlawful voters.”  This despite the often – shown problems in searching for non-voters due to inconsistent, out of date, mistakenly matched records.

In all of this, why to bureaucrats go along with the idee fixe that there are loads of illegal voters? The bureaucratic mentality after years of experience boils down to perfectly applying orders from above.