Democratic governors and state attorneys general are clearing the playbooks of their offices’ responses to President-elect Donald Trump’s policies, but they know it could be a tougher fight in his second term in office.

Trump’s campaign promises included mass illegal deportations of people in the country, and his history includes Roe v. It includes rolling back environmental regulations and paving the way for state abortion bans by nominating three new Supreme Court justices who helped overturn the Wade case.

All this makes liberals nervous and believe that organized resistance is necessary.

Democratic state officials are positioning themselves to make that happen.

California Governor Gavin Newsom last week called for a special legislative session to accelerate efforts to “Trump-proof” laws in the nation’s most populous state.

The Democratic governors of Colorado and Illinois announced Wednesday a nationwide effort calling on Governors to Protect Democracy.

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Let’s take a look at how states worked against Trump policies last time and what that might look like in his second term.

Democrats shut down or changed some policies last time

Over the past two decades, challenging the opposing party’s president’s policies has become an important part of state attorneys general’s job.

That number peaked when Trump first took office, with 160 multi-state filings against the administration in four years, according to a tally kept by Marquette University political scientist Paul Nolette.

This was twice as many applications as faced by President Barack Obama’s administration twice; almost all of it came from GOP attorneys general. Republicans have filed 142 lawsuits against President Joe Biden’s administration.

Multistate legal actions against Trump’s policies have been successful 94 times.

Some victories were temporary. For example, Democrats initially persuaded the courts to block the president’s travel ban from many Muslim-majority countries, but the U.S. Supreme Court eventually upheld it.

Other gains were on relatively mundane matters. In one case, a petition to pressure regulators to stop delaying rules on ceiling fan efficiency prompted the U.S. Department of Energy to do so.

Governors and legislators also have roles. During Trump’s first presidency, for example, California and some other states passed laws limiting how much assistance local officials could provide to federal immigration authorities.

Trump, on the other hand, may need help from GOP officials to carry out his policies. For example, he could ask governors to mobilize the National Guard to carry out deportations, which he said would begin on the day he is sworn in.

There are now significant differences in the legal environment

Washington’s Democratic governor-elect and current attorney general, Bob Ferguson, said at a news conference last week that Democratic attorneys general’s offices have been in contact for months to talk about how to push back against Trump’s policies.

He said it was relatively easy for Republicans to defeat the Trump administration in court early in its first term.

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“Management was often careless in implementing its actions. “That gave us the ability to prevail in court,” Ferguson said. “I predict we’ll see less of it this time.”

“What’s different is the much higher level of sophistication on both sides,” said James Tierney, a former Maine attorney general who teaches in the office at Harvard Law School.

Ferguson will be one of a handful of people who served as attorney general at the beginning of Trump’s first term and became governor in his second term. When Trump is inaugurated on January 20, none of the Democratic attorneys general or governors from 2017 will be in the same job.

Courts have also become more conservative since Trump took office — thanks in large part to his efforts. Trump appointed 245 judges to federal courts, including three to the U.S. Supreme Court.

Wars won’t just be in the courts

Marquette’s Nolette said Democratic attorneys general will be involved in the “entire lifecycle” of policies.

They will have staff submit comments opposing regulations that government agencies develop to enforce and interpret laws, and then file lawsuits if those regulations are enacted.

Offices are likely to act aggressively in combating claims that new federal laws are unconstitutional. Nolette said the most productive action would be to go to court for enforcement proceedings, and said this could come into play especially in immigration cases.

“They tend to be legally vulnerable by nature,” he said.

Nolette said there are other ways attorneys general can exercise power over federal policy besides challenging federal actions.

One of these is to sue companies and reach a settlement. States have used this approach, for example, to force the pharmaceutical industry to change practices regarding opioids without any federal legislation or administrative action.

Although states cannot enter into agreements, they can do things like sign international climate agreements.

If the federal government rolls back enforcement in areas such as environmental laws, states could step up enforcement of similar laws.

Political ambitions come into play here too

Democratic officials leading the charge against Trump could be thrust into the spotlight, which could help them land political jobs in the future.

California Attorney General Rob Bonta is likely to be at the center of the action this time.

Many other Democratic officials, including Attorney General Letitia James of New York and Josh Kaul of Wisconsin, whose voters went for Trump in 2016 and 2024, have held news conferences or issued news releases about their determination to fight Trump policies.

Illinois Gov. J.B. Pritzker and Colorado Gov. Jared Polis on Wednesday announced a new grant-funded effort called Governors Protecting Democracy aimed at helping states uphold the rule of law. Some Democrats have said that would be at risk if Trump becomes president.

“We founded the GSD because we know that simple hope alone will not save our democracy,” Polis said in a conference call with reporters.