1. United States
2. N.J.
3. Letter

The State of New Jersey and the Township of Roxbury come to this Court to seek relief from the unlawful decision of the U.S. Department of Homeland Security (DHS) and Immigration and Customs Enforcement (ICE) to establish a large-scale immigration detention facility in an industrial warehouse in Roxbury (the “Roxbury Warehouse”). In their rush to expand detention capacity across the country, DHS and ICE have flouted bedrock federal statutory mandates with which Congress requires it to comply: the Administrative Procedure Act (APA), 5 U.S.C. § 701, et seq.; the National Environmental Policy Act (NEPA), 42 U.S.C. § 4321, et seq.; the Intergovernmental Cooperation Act (ICA), 31 U.S.C. § 6506(c); and the Immigration and Nationality Act (INA), 8 U.S.C. § 1231(g). Any one of these violations requires vacating the Case 2:26-cv-02884 Document 1 Filed 03/20/26 Page 1 of 50 PageID: 1 2 decision to establish an immigration detention facility at this site and restraining further steps to construct one; together, the need for judicial intervention is overwhelming. 2. Seeking to put into practice the Executive’s plan to treat deportation as a “business” that operates “like (Amazon) Prime, but with human beings,” DHS has made the final decision to establish a mass detention facility at the Roxbury Warehouse. There is no doubt of the finality of that plan: DHS has purchased the site, has confirmed the site will be converted to an immigration detention center, and is evidently soliciting construction bids to start work. Nor is there any doubt that the Roxbury Warehouse is not fit for detention. The Roxbury Warehouse is a logistics center fit for Amazon Prime packages, not people—among other things, it currently has a total of four toilets, despite the planned influx of up to 1,500 detainees and hundreds more ICE employees. Indeed, the influx of up to 1,500 detainees requiring potable water and sewage conveyance would strain beyond capacity the local water and sewage systems, threatening water availability and risking sewage overflows into land and water. The construction required to further establish the site as a detention center would have major environmental impacts to boot. And the health care needs at DHS detention facilities, which have been vectors for disease outbreaks, would risk quickly overwhelming Roxbury’s two-ambulance volunteer Emergency Medical Service. 3. It is thus unsurprising that DHS’s decision to establish a mass detention facility at the Roxbury Warehouse has drawn such powerful opposition across the political and ideological spectrum. Although state and local officials were not consulted by DHS in advance of its decision to develop a 1,500-person detention facility at the warehouse site, they reacted swiftly