Federal preemption—when federal law supersedes state law—is among the most enigmatic and frequent legal issues facing federal courts. Although the application of federal preemption has been the subject of much scholarly discussion, little research has focused on the causes of the rising litigation in this field. This paper aims to do just that by investigating the ongoing federal court case involving Texas Senate Bill 4. It argues that federal preemption is often misconstrued in a way that exonerates the root cause of preemption litigation: Congressional inactivity. Analyzing previous immigration preemption cases and the current United States v. Texas case, I demonstrate that preemption litigation has been framed as an inherent power struggle between Courts, the President, and the States, by incentivizing lawmaking activity. The findings indicate that congressional dysfunction weighs down at least parts of the U.S. legal system and fosters a legislative climate where states and the executive branch are driven to push the limits of the law. In contributing to the literature on preemption doctrine and legislative reform, this analysis emphasizes the urgent need for Congressional action to alleviate the legal and policy instability in the U.S. immigration system.