President Obama appears to have a backup plan in case federal courts keep blocking his 2014 executive actions to provide work permits for millions of illegal immigrants and allow them to avoid deportation, according to a leaked Department of Homeland Security document.

The document was obtained by the Immigration Reform Law Institute and first reported by The Hill newspaper.

According to the internal memo, the administration is floating four options for dealing with an uncooperative court system -- including one giving so-called Employment Authorization Documents to "all individuals living in the United States," including illegal aliens, visa-overstayers, and H-1B guest-workers. A narrower option would give them only to those in the U.S. with unexpired non-immigrant visas.

"If this administration was half as determined to uphold immigration laws as it is to undermining them, our borders would be secure, sanctuary cities would cease to exist, and criminal immigrants would be deported instead of being released back into our neighborhoods," said Texas GOP Rep. Lamar Smith, a former chairman of the House Judiciary Committee. "This memo shows the great lengths to which DHS officials have gone in order to defy a federal judge’s orders."

The memo was prepared as follow-up from a DHS "Regulations Retreat" last summer, according to The Hill.

Obama last year issued two executive orders that would grant the temporary work permits to millions of parents of American citizens and young people brought into the U.S. illegally.

In February, a Texas federal judge ordered a halt to the administration's Deferred Action for Parents of Americans and expanded Deferred Action for Childhood Arrivals programs, in response to a suit filed by 26 states.

The administration appealed the decision, which is now being reviewed by a three-judge panel in the Fifth Circuit Court of Appeals in Louisiana.