Democratic governors and state attorneys general are dusting off tactics from their offices against President-elect Donald Trump’s policies, but they know the battle could be tougher in his second term.

Trump’s campaign promises included mass deportations of people in the country illegally, and his history includes rolling back environmental regulations and laying the groundwork for the state’s ban on abortion by appointing three new judges to the Supreme Court who helped overturn Roe v. Wade.

All of this puts liberals on alert – and makes them believe that organized resistance is necessary.

Democratic state officials are positioning themselves to do just that.

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

Democratic governors in Colorado and Illinois announced a national effort Wednesday that they call governors saving democracy.

Here’s a look at how states worked against Trump’s policies last time, and how it could play out during his second term.

Democrats saw some policies reversed or changed last time

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

It peaked the first time Trump was in office, with 160 complaints filed in several states against the administration in four years, according to a tally compiled by political scientist Paul Nolette of Marquette University.

That’s twice as many cases as President Barack Obama’s administration had to process in twice the time, almost all of them from GOP attorneys general. Republicans have filed 142 complaints against President Joe Biden’s administration.

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

Some victories were fleeting. For example, Democrats initially persuaded the courts to block the president’s ban on travelers from several Muslim-majority countries, but the U.S. Supreme Court ultimately upheld that decision.

Other victories involved relatively mundane matters. In one case, a request to push regulators to stop delaying rules on ceiling fan efficiency prompted the U.S. Department of Energy to do so.

There are also roles for governors and legislators. For example, during Trump’s first presidency, California and some other states passed laws limiting the assistance that local authorities could provide to federal immigration agents.

On the other hand, Trump may need help from Republican officials to carry out his policies. For example, he could ask governors to activate the National Guard to carry out the evictions that he said would begin the day he was sworn in.

There are currently key differences in the legal landscape

Bob Ferguson, the Democratic governor-elect of Washington and current attorney general, said at a news conference last week that Democratic attorneys general’s offices have been in contact for months to discuss how to combat Trump’s policies .

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

“They have often been negligent in how they have deployed their executive actions. And that gave us the opportunity to win in court,” Ferguson said. “This time around, I anticipate we’ll see less of that.”

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

Ferguson will be one of the few people who served as attorney general early in Trump’s first term to become governor in his second. None of the 2017 Democratic attorneys general or governors will hold the same position when Trump takes office on January 20.

The courts have also become more conservative since Trump took office – largely due to his efforts. Trump has appointed 245 judges to federal courts, including three to the U.S. Supreme Court.

The battles won’t just be fought in the courts

Marquette’s Nolette said Democratic attorneys general would be involved in “the full life cycle” of policies.

They will ask their employees to submit comments opposing regulations proposed by government agencies to enforce and interpret laws, and then sue if and when those regulations take effect.

The offices will likely be aggressive in challenging the new federal laws as unconstitutional. Nolette said the most fruitful course of action might be to go to court for executive actions — something he said could especially come into play with immigration actions.

“By their nature, they tend to be legally vulnerable,” he said.

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

One way is to file lawsuits and reach settlements with the companies. States have used this approach to force the pharmaceutical industry to change its practices regarding opioids, for example, without any federal law or executive action.

And even if states cannot conclude treaties, they can, for example, sign international climate agreements.

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

Political ambitions come into play here too

Democratic officials leading the charge against Trump could get time in the spotlight, which could help them land future political jobs.

California Attorney General Rob Bonta will likely be at the center of the action this time around.

Several other Democratic officials, including Attorneys General Letitia James of New York and Josh Kaul of Wisconsin – whose voters favored Trump in 2016 and 2024 – have held news conferences or issued press releases about their commitment to fight against Trump’s policies.

Illinois Governor JB Pritzker and Colorado Governor Jared Polis on Wednesday announced a new effort called Governors Safeguarding Democracy, funded by donations and aimed at helping states protect the rule of law – which , according to some Democrats, will be threatened with Trump as president.

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