Maryland v. Mullin
ELR Citation: 56 ELR 20056 No(s). 26-733-BAH (D. Md. Apr 17, 2026) (Hurson, J.)
A district court granted the state of Maryland's motion for preliminary injunction in a challenge to federal agencies' plans to convert a vacant commercial warehouse into an immigration detention facility. The state argued the agencies violated NEPA by failing to prepare any environmental document prior to purchasing the warehouse for their intended purposes and that absent meaningful public engagement, they had fallen short of the "hard look" required. The agencies argued they complied with NEPA by applying three categorical exclusions to the acquisition and retrofitting of the warehouse for its initial capacity of 540 detainees. The court found that even under the highly deferential review required by Seven County Infrastructure Coalition v. Eagle County, the agencies failed to comply with the NEPA, and that the state met its burden of showing a clear likelihood of imminent irreparable harm. It granted the motion for preliminary injunction and enjoined the agencies from construction and renovation for purposes of operating the warehouse as a detention and processing facility.