As long as the Court remains conservative, the chances of legislation to penalize or force States or Cities into helping ICE or the FBI on enforcing Federal laws in violation of the US Consittution are zilch. There are two cases by Scalia that point to this. One dealt with enforcement of Federal Gun Laws by states. Scalia said that the Feds could not require states and cities to enforce federal gun laws and Scalia noted the general rule that the Feds could not have States or city's enforce federal laws.