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- The administration has launched an "administrative cold civil war" using 255 executive orders and the reclassification of up to 50,000 federal roles to centralize power and bypass...
The administration has launched an "administrative cold civil war" using 255 executive orders and the reclassification of up to 50,000 federal roles to centralize power and bypass...
...traditional civil service protections. Governance is defined by intense institutional friction, defiance of court mandates in 35% of adverse rulings and the use of regulatory investigations.
Summary: The administration has launched an "administrative cold civil war" using 255 executive orders and the reclassification of up to 50,000 federal roles to centralize power and bypass traditional civil service protections.
This strategy has triggered a regional economic crisis in the Washington D.C. area, where over 53,800 federal jobs were lost in a single year and the regional unemployment rate reached 4.4% by early 2026.
Governance is currently defined by intense institutional friction, marked by the executive’s defiance of court mandates in approximately 35% of adverse rulings and the use of regulatory investigations to retaliate against media critics.
Structural Institutional Conflict and the Transformation of the American State: A Geopolitical Risk Assessment of the Administrative Cold Civil War
by Gemini 3.0, Deep Research. Warning, LLMs may hallucinate!
The governance of the United States in 2026 has entered a phase of systemic institutional conflict that transcends traditional political polarization, evolving into what can be analytically characterized as an administrative cold civil war.1 This conflict is defined by a struggle between two asymmetrical camps over the control of the state’s core operating systems, including the civil service, the regulatory apparatus, the judiciary, and the infrastructure of domestic surveillance.1 The current executive administration has adopted a strategy of centralized, executive-directed governance designed to convert the administrative state into a more responsive instrument of political will.1 This project has encountered profound institutional resistance from a loose coalition of democratic states, civil-service unions, non-governmental organizations, and the federal judiciary, creating a persistent state of institutional friction that threatens the long-term stability of American governance.1
The evidence for this shift is rooted in the aggressive use of executive orders, the systematic reclassification of the federal workforce, and a pattern of noncompliance with judicial mandates.1 As of early 2026, the second Trump administration has published 30 executive orders within the first quarter alone, following 225 orders in 2025, reflecting an unprecedented reliance on executive fiat to implement structural reforms.1 This strategy is characterized by a “personnel-is-policy” approach that seeks to intimidate or replace the professional bureaucracy with loyalist appointees, while simultaneously utilizing regulatory procedures to retaliate against critics in the media, law firms, and academia.1 This report provides an exhaustive analysis of the mechanisms, economic consequences, and geopolitical implications of this ongoing administrative struggle.
The Executive Offensive: Reconfiguring the Administrative State through Unilateral Action
The primary mechanism of the administrative cold civil war is the expansion of executive power through the strategic use of unilateral instruments. The administration’s reliance on executive orders and regulatory reversals is not merely a method of policy implementation but a structural move to centralize authority within the White House.1 By bypassing the traditional legislative process, the executive branch has initiated a sweeping effort to remove Biden-era actions and implement novel deregulatory measures.5

The volume of executive actions, as recorded in the Federal Register, indicates a governance model that views administrative rules as tactical obstacles rather than binding constraints.1 This is further supported by the Migration Policy Institute’s finding that during the first year of the administration, 17% of all executive orders were specifically related to immigration, reflecting the use of border enforcement as a central pillar of the administrative offensive.1
This centralization effort is aimed at reducing institutional resistance to policy implementation. The administration’s rhetoric frames the permanent bureaucracy as a “deep state” power network that exerts influence beyond the reach of political leadership.2 By conceptualizing the bureaucracy as an elite faction operating covertly, the administration justifies radical reforms intended to replace traditional meritocracy with political loyalty.2 These measures have exacerbated social divisions and political polarization, leading to a state where the operating system of the state itself is a battlefield.1
Personnel Warfare and the Erasure of Civil Service Protections
Central to the administration’s strategy is the systematic weakening of the professional, non-partisan civil service. For over a century, the American administrative state functioned on the principle of neutral competence, shielded from political interference by the merit-based protections of the competitive service.6 The current administration has aggressively sought to dismantle these protections, viewing the “neutrality” of the bureaucracy as a form of institutional obstruction.1
The most significant structural shift in this regard is the reclassification of federal workers. On February 6, 2026, a rule was finalized to lower the barrier for reclassifying civil servants from the competitive service to the “excepted service”.6 This move, which went into effect on March 9, 2026, clarifies that an employee’s civil service protections can be involuntarily removed, effectively making these positions “at-will” employment.6
This policy, often referred to as Schedule F, targets up to 50,000 federal workers who occupy roles involving policy-making or confidential advice.1 By removing the opportunity for appeal and the requirement for “cause” in dismissals, the administration has created a framework to purge perceived opponents and install a more loyal, centralized workforce.1 This transformation is already observable in the Department of Homeland Security and the Department of Justice, where reporting indicates the replacement of immigration judges in ways that align the legal system more closely with the administration’s deportation objectives.1
The implications of this personnel warfare extend beyond individual job losses. The loss of institutional knowledge—accelerated by programs like the “Fork in the Road” deferred resignation program—weakens the state’s ability to manage complex regulatory tasks, ranging from financial oversight to environmental protection.8 This hollowing out of the state’s human capital represents a long-term risk to the continuity and stability of American governance.
Economic Destabilization of the Federal Core: The DMV Regional Crisis
The administrative civil war has had profound and immediate economic consequences, particularly in the regions most dependent on federal employment and funding. The Washington, D.C. metropolitan area (the DMV), which includes parts of Maryland and Virginia, has faced acute harms due to the concentration of federal workers and contractors.8
Quantitative Analysis of Regional Employment Trends
Between the end of 2024 and 2025, federal employment in the DMV region fell by 53,800 jobs, a decrease of 14.2%.8 Nationally, the reduction was even more significant, with over 350,000 federal government positions lost between January 2025 and March 2026.8 These losses have reverberated through the regional economy, affecting a non-federal workforce of over three million people who work at firms that consult with, contract for, or are otherwise connected to the government.8

The data indicates that the employment rate in the DMV fell by at least 2 percentage points across every demographic category in 2025.8 The decline was most severe among Black workers, erasing recent progress in closing the regional Black-white employment gap.8 Furthermore, the regional unemployment rate jumped from 3.1% in January 2025 to 4.4% in January 2026, even as the local labor force shrank by 3%, suggesting a significant exodus of residents from the region.8
Cascading Effects on the Private and Nonprofit Sectors
The administrative offensive has not been limited to direct federal employment. The administration has terminated thousands of grants to scientific research institutions and frozen funding for tens of thousands of nonprofits.8 As a region with one of the highest concentrations of nonprofits and research entities, the DMV has been disproportionately affected.8
Furthermore, the administration has moved to cancel contracts with any company that maintains a commitment to diversity, equity, and inclusion (DEI) standards.8 This has contributed to a 0.3% dip in private-sector employment in the DMV during a period when the national private sector grew by 0.5%.8 The regional housing market has also shown signs of instability, with the DMV seeing the largest increase in home sale listings of any major metro area in 2025, further indicating a potential mass departure of the professional class.8
The passage of the “One Big Beautiful Bill Act” (OBBBA) has added fiscal pressure by constraining the ability of the District of Columbia to spend its own tax revenue.8 This congressional interference jeopardizes nearly $700 million in local revenue, potentially forcing changes to the local tax code and further destabilizing the regional economy.8
The Regulatory Battlefield: Targeted Deregulation and Institutional Capture
The administration’s regulatory strategy is characterized by a “two-pronged” approach: the systematic reversal of previous policies and the gutting of the enforcement mechanisms of independent agencies.5 This strategy is tracked extensively by the Brookings Center on Regulation and Markets, which has documented significant changes across environmental, health, labor, and financial policy.6
Financial Deregulation and the Retreat of Enforcement
A wave of financial deregulation is currently underway at agencies including the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), and the Consumer Financial Protection Bureau (CFPB).9 The IRS, in particular, has seen its enforcement budget slashed and its workforce reduced by over one-quarter in a single year.9

The consequences of these cuts are tangible. The SEC has dismantled several teams responsible for managing incidents of scams and frauds, while the CFPB has shifted sharply away from its enforcement efforts.9 Across the government, the administration has halted or dropped 176 enforcement actions that were pending against corporations.9 This retreat from enforcement effectively changes the “landscape” of the American economy, prioritizing corporate autonomy over consumer and investor protection.9
Specific Regulatory Reversals as of March 2026
The Brookings “Reg Tracker” highlights several key areas where the administration has successfully overturned or rescinded major regulations:
Noncompete Clauses: On February 12, 2026, the FTC released a final rule to remove the noncompete clause rule, restoring regulations to their prior status and allowing firms to once again limit worker mobility.6
Environmental Standards: The administration has moved to rescind the greenhouse gas endangerment finding and vehicle emissions standards, signaling a total retreat from climate-oriented regulation.6
Negative Option Rules: The “click to cancel” rule, which combated deceptive practices in automatic renewals and free trials, was rescinded on February 12, 2026, to align with court decisions that favored industry groups.6
Immigration Vetting: New rules were implemented in March 2026 to enhance vetting and combat fraud in the Diversity Immigrant Visa Program, adding additional hurdles for applicants.6
These actions are often presented as “aligning regulations with court decisions,” reflecting a tactical synergy between the executive branch and a sympathetic judiciary.6 However, the speed and breadth of these changes have created a “tumultuous retreat” for agency staff, who are forced to master complex new code changes while operating with significantly reduced resources.9
Administrative Retaliation: The Weaponization of Regulatory Procedure
A defining feature of the administrative cold civil war is the use of government machinery to retaliate against private-sector critics and civil society organizations.1 This tactic—often described as “intimidation-by-procedure”—seeks to send a message to institutional actors that opposition to the administration will carry significant regulatory costs.1
The FCC Investigation of ABC Broadcasting Licenses
A textbook example of this retaliatory governance occurred on April 28, 2026, when the Federal Communications Commission (FCC) announced the accelerated review of eight local broadcasting licenses owned and operated by ABC.10 These stations, located in major markets like New York, Los Angeles, and Chicago, were originally scheduled for renewal between 2028 and 2031, but the FCC required them to file for renewal by May 2026.10
This acceleration followed a joke made by late-night host Jimmy Kimmel about the former First Lady and subsequent calls from Donald Trump for Kimmel to be fired.10 The FCC justified the move by citing an investigation into the diversity, equity, and inclusion (DEI) practices of Disney, suggesting that categorization of employees by race and gender could raise “character questions” about the company.10 Internal dissent from Democratic Commissioner Anna M. Gomez described the move as an “unprecedented, unlawful” political stunt, while legal experts characterized it as “illegal jawboning” designed to consolidate government control over media content.10
The stations targeted for accelerated review include:
WABC-TV (New York)
KABC-TV (Los Angeles)
WLS-TV (Chicago)
WPVI-TV (Philadelphia)
KTRK-TV (Houston)
KGO-TV (San Francisco)
WTVD-TV (Raleigh-Durham)
KFSN-TV (Fresno) 10
Even if the FCC ultimately fails to revoke these licenses, the process itself creates a chilling effect on other licensees.1 This represents a normalization of using administrative levers as weapons of political retribution, a practice that CPJ warns threatens the public’s right to know.1
The Judicial Crisis: Legal Noncompliance and Constitutional Friction
The administrative cold civil war is perhaps most acute in the conflict between executive power and judicial restraint. The administration has engaged in what is described as more administrative and constitutional friction with the judiciary than any administration in modern history.11
Quantitative Assessment of Litigation and Defiance
The scale of legal challenges against the administration is unprecedented. By January 3, 2026, the Associated Press was tracking 358 active cases.3 Other organizations, such as Just Security, reported as many as 552 cases as of early 2026.3 A Washington Post analysis found that the administration defied, delayed, or frustrated court oversight in approximately 35% of the cases ruled against them.3

Reporting indicates that district judges have found the administration in violation of court orders in at least 31 lawsuits, with more than 250 instances of noncompliance recorded in individual immigration cases.1 These cases involve a broad range of subjects, including federal funding cuts, deportations, and the management of foreign aid.1 The administration has frequently argued that it can bypass international treaties, such as the Convention Against Torture, if third countries provide “diplomatic assurances” that individuals will not be persecuted.12
Significant Rulings and Executive Aggrandizement
One of the most significant legal defeats for the administration occurred on February 20, 2026, when the U.S. Supreme Court ruled 6-3 in Learning Resources Inc. v. Trump.3 The Court determined that the International Emergency Economic Powers Act (IEEPA) does not grant the President the power to set tariffs unilaterally.3 This ruling consolidated challenges from small businesses and states who argued the administration’s use of IEEPA to impose tariffs was illegal and unconstitutional.3
Despite such rulings, the administration has continued to challenge the constitutional authority of Congress, particularly regarding the 1974 Impoundment Control Act.11 Trump and his allies argue that the authority to withhold federal funds was “unjustly stripped” from the presidency and have repeatedly bypassed congressional spending mandates.11 The Government Accountability Office (GAO) has noted multiple violations of this Act, further fueling the perception of a constitutional crisis.11
The Infrastructure of Surveillance: Data Fusion and Technological Control
The “cold” nature of the administrative conflict is facilitated by the expansion of the state’s surveillance and data-gathering capabilities. While ICE is the visible edge of this infrastructure, the deeper reality involves a sophisticated network of data fusion, AI analytics, and private contractors.1
AI and Biometrics in Domestic Enforcement
The Department of Homeland Security has accelerated investment in AI for ICE with limited public scrutiny.1 This infrastructure includes the use of DHS data fusion, biometrics, social media monitoring, and mobile-location databases purchased from private contractors.1 These tools allow for a more centralized and executive-directed enforcement mechanism that can bypass traditional investigative constraints.
The American Immigration Council and EPIC have warned that the DOJ is doggedly pursuing sensitive voter-roll data from 47 states and the District of Columbia.13 Internal sources indicate that the DOJ plans to share this voter data with DHS/SAVE systems for use in immigration and criminal investigations.15 This represents a merger of immigration enforcement, election administration, and surveillance infrastructure, creating a powerful tool for political and social control.1
The Balkanization of Electoral Administration
The administrative civil war has extended into the management of elections, with state-level actors increasingly using the machinery of government to secure partisan advantages. This is most evident in the “mid-decade redistricting” efforts undertaken by both Republican and Democratic states in advance of the 2026 midterms.1
Competitive Gerrymandering and Voter Sovereignty
Prompted by requests from the President, Republican leaders in Texas, Missouri, and North Carolina passed new electoral maps in 2025 with the aim of securing approximately seven additional seats for Republicans.16 In response, California Democrats enacted their own map, which was expected to add five Democratic seats.16 This cycle of “competitive gerrymandering” reflects a breakdown in the decennial census tradition and a move toward permanent, tactical map-making.1

The electoral framework is further strained by executive orders attempting to federalize election rules. In March 2025, an order was issued requiring voters to provide proof of citizenship and imposing federal oversight on state vote-counting.16 Although challenged for exceeding presidential authority, the order signaled an intent to use administrative levers to shape the electorate.16 These developments have led Freedom House to award the U.S. its lowest freedom score since the project began in 1972.17
Propaganda and the Delegitimization of Institutions
The administrative conflict is accompanied by a layer of “legitimacy warfare” that seeks to redefine the role of expertise, journalism, and law in society.1 This is not merely a matter of political messaging but a systematic delegitimization of any institution that provides a check on executive power.1
The administration has repeatedly characterized judges, journalists, universities, experts, and civil servants as “enemies,” “Marxists,” or “corrupt insiders”.1 This rhetoric is designed to prepare the public to accept exceptional measures against these individuals and institutions.1 The CPJ has expressed concern over the intimidation of news outlets, noting that such attacks threaten the fundamental public right to know.1
This propaganda effort is often paired with the concept of the “Deep State”—a persistent power network of unelected bureaucrats that the administration claims must be dismantled.2 Supporters of this view commend these measures as a courageous effort to combat entrenched corruption, while critics argue they threaten the system of checks and balances and foster the development of an authoritarian regime.2
Conclusion: The Institutionalization of Systemic Instability
The “administrative cold civil war” is a diagnostic reality of the American state in 2026. It is a struggle in which rival political coalitions use the machinery of government, the courts, personnel rules, surveillance infrastructure, and legitimacy narratives to capture or disable each other’s institutional power.1 The most dangerous aspect of this conflict is its normalization.1 Once every administrative lever is converted into a weapon, future governments inherit a playbook that prioritizes institutional sabotage over stability.1
The hollowing out of the federal workforce, the defiance of judicial mandates, and the weaponization of regulatory procedures have created a governance model defined by executive aggrandizement.11 For corporate and geopolitical actors, this represents a fundamental shift in risk. The primary concern is no longer just policy volatility but the potential for a total breakdown in the rule of law and the functional capacity of the state.2 As the 2026 midterm elections approach, the American political system remains locked in a struggle over the very operating system of the state, with long-term implications for the stability of the global order.
Works cited
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Reform of the American Bureaucratic System from the Perspective of the “Deep State” Theory - Atlantis Press, accessed May 2, 2026, https://www.atlantis-press.com/article/126022558.pdf
Legal affairs of the second Trump presidency - Wikipedia, accessed May 2, 2026, https://en.wikipedia.org/wiki/Legal_affairs_of_the_second_Trump_presidency
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What will deregulation look like under the second Trump administration? | Brookings, accessed May 2, 2026, https://www.brookings.edu/articles/what-will-deregulation-look-like-under-the-second-trump-administration/
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FCC orders review of ABC licenses after Jimmy Kimmel’s Melania ..., accessed May 2, 2026, https://www.theguardian.com/us-news/2026/apr/28/fcc-abc-jimmy-kimmel
U.S. Democratic Backsliding in Comparative Perspective | Carnegie ..., accessed May 2, 2026, https://carnegieendowment.org/research/2025/08/us-democratic-backsliding-in-comparative-perspective
REPORT ON THE TRUMP ADMINISTRATION’S 2025-26 CHANGES TO IMMIGRATION LAW (Last updated January 26, 2026) - New York City Bar Association, accessed May 2, 2026, https://www.nycbar.org/wp-content/uploads/2025/10/20221419-TrumpAdminChangesImmigrationLaw_updated_1.26.2026.pdf
ICE Uses a Growing Web of AI Services to Power Its Immigration Enforcement and Surveillance, accessed May 2, 2026, https://www.americanimmigrationcouncil.org/blog/ice-uses-ai-immigration-enforcement-surveillance/
DOJ Wants Sensitive Voter Data But Can’t Be Bothered to Protect It - Epic.org, accessed May 2, 2026, https://epic.org/doj-wants-sensitive-voter-data-but-cant-be-bothered-to-protect-it/
Justice Dept. close to finalizing deal to hand over states’ voter roll data to Homeland Security, sources say - CBS News, accessed May 2, 2026, https://www.cbsnews.com/news/justice-dept-finalizing-deal-voter-roll-data-homeland-security/
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