Sanctuary within the Context of Immigration Law Enforcement
- Human Rights Research Center
- May 2
- 20 min read
Author: Mary D'Alleva, MA/MFA
May 2, 2025
With recent high profile immigration enforcement actions taken by the United States Federal government, the idea of “sanctuary” and the socio-political application of the term are once again being prominently featured in both domestic and international news. Sanctuary is commonly thought of as being a place where undocumented immigrants might find refuge from arrest, deportation, or from being taken into custody unlawfully. Sanctuary “entities” (e.g., states, cities, counties, institutions of worship, and educational institutions) limit cooperation with federal immigration authorities through the utilization of non-compliance as a response to requests to detain, pursue, or report undocumented immigrants who have had contact with local law enforcement. As of March 2025, thirteen states and 220 cities and counties have claimed “sanctuary” status; some of the cities and counties fall within states that are not identified as “sanctuary” (Vaughan & Griffith, 2025).
The history of sanctuary cities in the United States traces back to slavery in the 1790's. Slave holders claimed that existing federal law, the Fugitive Slave Act of 1793 which allowed slave owners to re-capture escaped slaves, was insufficient to guarantee what they considered their rights (Baker, 2017). These slave owners demanded that state officers (e.g., law enforcement, judges) be compelled to enforce the federal Fugitive Slave Act and return what they considered as their constitutional right to “property.” An 1818 attempt to revise the Fugitive Slave Act failed partly because the proposed bill required state officers to enforce federal law, which contradicted the understanding that federal and state governments were each sovereign in their respective domains, and that each domain was entirely separate (as outlined in the Tenth Amendment of the United States Constitution, ratified 1791). While Congress might direct federal law enforcement officers and judges, Congress was not authorized to direct state officers, and vice versa, thus reinforcing a clear boundary between federal and state jurisdictions, and further establishing limits of federal authority at the state level. At that time, the abolitionist governments of northern states were beginning to provide instructions to civilians on how to handle refugee slaves. In Prigg v. Pennsylvania (1842), the Supreme Court further secured the principle of dual sovereignty in Constitutional law. In their ruling, fugitive slaves [“undocumented people”] were deemed a federal matter, rather than a state one, meaning states could not pass laws to protect the legal rights of fugitive slaves or to aid in their removal and transportation back to the slaveholders. However, with this ruling, the opposite also remained true, as the Supreme Court reaffirmed that Congress could not force state officers to enforce federal law (Baker, 2017). More recently, cities such as San Francisco passed ordinances in the 1980’s that forbade city police from assisting federal immigration officers in response to federal immigration policies denying asylum to refugees from El Salvador and Guatemala (Baker, 2017). In Donald Trump’s first term as president in 2017, the idea of sanctuary again was called into question. Sanctuary cities fought an executive order that would deny them federal funds. In 2025, we find ourselves in the same place - with states and cities filing suit against the federal government.
Sanctuary is legally complex, in addition to being both an emotionally and a politically charged term. The idea of “sanctuary” has become a political tool that does not necessarily address the reality of what protections sanctuary provides in its legal application can, or what it can't, provide. The debate around “sanctuary” highlights the tension in the United States between state and federal jurisdiction. This tension can be illustrated through the lens of the Constitution and Supreme Court rulings. According to the U.S. Supreme Court’s website, “The Court is the highest tribunal in the Nation for all cases and controversies arising under the Constitution or the laws of the United States. As the final arbiter of the law, the Court is charged with ensuring the American people the promise of equal justice under law and, thereby, also functions as guardian and interpreter of the Constitution” (About the Court - Supreme Court of the United States, n.d.). Discussing “sanctuary” necessitates looking at how federal and state jurisdictions co-exist.
Within the United States, there is not one clear definition of what it means for a state or local government to adopt sanctuary policies. In fact, while they are referred to as “policies,” no legal standard of the term exists. In general, sanctuary policies limit cooperation with federal immigration officials but do not actively prevent federal officials from carrying out their immigration enforcement duties. Limits may include: restricting the ability of police to make arrests for federal civil immigration violations; detaining individuals on civil immigration warrants or to enforce federal immigration law; preventing local governments from entering into a contract with the federal government to hold immigrants in detention; restricting the police or other city workers from asking about immigration status; restricting the sharing of certain information on immigrants with the federal government, and refusing to allow Immigration and Customs Enforcement (ICE) into local jails without a judicial warrant. One of the most common sanctuary policies is a restriction on holding immigrants in state or local jails following a “detainer” issued by ICE. A detainer is an official but non-binding request from ICE that a state or local law enforcement agency maintain custody of an individual for up to 48 hours beyond the time the individual otherwise would have been released so that ICE can arrange to take over custody (Sanctuary Policies: An Overview, 2025).
The viability of sanctuary cities relies upon the Tenth Amendment, which addresses the balance of power between federal and state governments. According to the Tenth Amendment, the federal government only has the powers delegated to it by the Constitution; states may have powers not forbidden by the Constitution. The potential for varied interpretations of the Tenth Amendment has resulted in many legal challenges and judicial interpretations throughout the history of the United States. Since the 1990’s, many Supreme Court rulings have favored states’ rights in their interpretations of the Tenth Amendment. Legal cases such as New York v. United States (1992), South Dakota v. Dole (1987), Printz v. United States (1997), Independent Business v. Sebelius (2012), and Murphy v. National Collegiate Athletic Association (2018) prohibited the federal government from forcing states to pass or not pass certain legislation which would enforce federal law. These cases formed what has come to be known as the “anti-commandeering doctrine” which prohibits the federal government from commandeering state and local resources to implement federal programs (Sanctuary Cities Face Legal Battles Over Federal Funding Restrictions). In Printz v. United States (1997), Justice Scalia reaffirmed that, “The Federal Government may neither issue directives requiring the States to address particular problems, nor command the States’ officers, or those of their political subdivisions, to administer or enforce a federal regulatory program.” (On This Day, the Supreme Court Reinforces the 10th Amendment, n.d.) The Court held that the federal government cannot compel states to enact or administer federal regulatory programs, regardless of the importance of the federal policy objectives. In Murphy v. NCAA (2018), Justice Alito wrote, “Conspicuously absent from the list of powers given to Congress is the power to issue direct orders to the governments of the States,” (On This Day, the Supreme Court Reinforces the 10th Amendment, n.d.). While these rulings establish a boundary on federal jurisdiction, the broad wording of the Constitution leaves room for Constitutional interpretation based on new situations (Overview of Approaches to Interpreting the Constitution | Constitution Annotated | Congress.gov | Library of Congress, n.d.). “This power of ‘judicial review’ has given the Court a crucial responsibility in assuring individual rights, as well as in maintaining a ‘living Constitution’ whose broad provisions are continually applied to complicated new situations” (Supreme Court of the United States, 2023). Federal judges are nominated by the President of the United States and confirmed by the Senate Judiciary Committee. This selection process may be influenced by politics as Presidents often select judges based on the priorities and policies of their administration (Shapiro, 2022).
On January 20th, 2025, President Trump issued the executive order “Protecting The American People Against Invasion” which threatens access to federal funds if cities or states do not comply with current immigration enforcement policies.
The Attorney General and the Secretary of Homeland Security shall, to the maximum extent possible under law, evaluate and undertake any lawful actions to ensure that so-called ‘sanctuary jurisdictions, which seek to interfere with the lawful exercise of Federal law enforcement operations, do not receive access to Federal funds. Further, the Attorney General and the Secretary of Homeland Security shall evaluate and undertake any other lawful actions, criminal or civil, that they deem warranted based on any such jurisdiction’s practices that interfere with the enforcement of Federal law (The White House, 2025).
President Trump continued with messaging on social media on April 10, 2025 that he plans to withhold all federal funds from sanctuary cities (Hadriana Lowenkron et al., 2025). However, in Independent Business (NFIB) v. Sebelius (2012), one of the “anti-commandeering doctrine” Supreme Court cases, the Supreme Court ruled that the Patient Protection and Affordable Care Act (“Obamacare”) unconstitutionally coerced states to expand Medicaid because it forced states to join the federal program by conditioning continued Medicaid funding on states agreeing to alter Medicaid eligibility standards. In NFIB v. Sebelius, the Supreme Court ruled that the federal government could not coerce states to comply by threatening to withhold funding. Chief Justice Roberts reinforced that “Congress has no authority to order the States to regulate according to its instructions. Congress may offer the States grants and require the States to comply with accompanying conditions, but the States must have a genuine choice whether to accept the offer,” (National Federation of Independent Business V. Sebelius | Constitution Center, n.d.). Justice Roberts further explained his interpretation of the Constitution, “The Framers created a Federal Government of limited powers, and assigned to this Court the duty of enforcing those limits,” (National Federation of Independent Business V. Sebelius | Constitution Center, n.d.).
In Arizona v. United States (2012) the Supreme Court upheld that federal immigration law, “the supreme law of the land,” preempts states from enforcing their own immigration policies (Institute for Constitutional Advocacy and Protection (ICAP), 2025). Recently, the Trump administration used the Immigration and Nationality Act of 1952 (INA) to justify such actions as the arrest of Mahmoud Khalil, a Columbia University student who helped organize campus protests. The INA is the “legal foundation of modern immigration law, encompassing a vast range of regulations and procedures” (Sullivan, 2025). Even though it has been amended many times over the years, it still contains rules allowing ideology to be used to deny immigration and allow deportation (Sullivan, 2025). However, the INA also provides for voluntary cooperation by state and local officials with federal immigration enforcement efforts. State and local officials may, but are not required to: communicate with the Department of Homeland Security (DHS) about the immigration status of any person, including whether a person is not lawfully present in the United States; cooperate with DHS in “identification, apprehension, detention, or removal” of people not lawfully present in the United States (ICAP, 2025b). While “sanctuary” may exist, it is important to remember that sanctuary policies are not recognized by the federal government. Sanctuary policies do not mean federal law enforcement cannot otherwise identify, investigate, or detain undocumented individuals in a “sanctuary city.” Sanctuary simply means that on a “local” or “community” level, law enforcement and local civil employees and practices may not present a threat to undocumented individuals.
While state and local entities may have the option of “voluntary” cooperation in immigration enforcement activities, it is a crime for state and local government or respective law enforcement to prohibit, prevent, or restrict federal access to information regarding citizenship or immigration status. However, it is not required that state or local entities inquire as to an individual’s immigration or citizenship status. In fact, in 2015 the Department of Homeland Security (DHS) explicitly indicated that state and local officers do not have the authority to investigate an individual's immigration status to communicate it to DHS. In the continual “see saw” that is state versus federal authority, information related “regarding the citizenship or immigration status, lawful or unlawful, of any individual” has been interpreted to apply solely to citizenship and immigration status, and not to other information that might be useful to federal immigration officials, such as the release date of those in state or local detention (ICAP, 2025c). This means that information not specific to immigration or citizenship status may be provided by “sanctuary” state and local authorities to the federal government, and could potentially lead to the detaining of individuals (ICAP, 2025c).
The Fourth Amendment protects against arbitrary arrests, and is the basis of the law regarding search warrants, stop-and-frisk, and other forms of surveillance. Under the Fourth Amendment, detention by a state or local law enforcement officer must be based on probable cause that a crime has been committed as determined by a neutral judge. Immigration warrants are not necessarily based on probable cause of a crime being committed; they are based on probable cause that the person is removable and are signed by an Immigration and Customs Enforcement agent, not a neutral judge. In Galarza v. Szalczyk (2014) the 3rd Circuit Court of Appeals ruled that ICE detainers are “merely requests” not mandates, and that state and local entities are free to disregard them, especially if they would lead to violation of Fourth Amendment rights. Galarza v. Szalczyk further upholds the Tenth Amendment in that federal immigration officials may not compel state and local officials to imprison people suspected of being unlawfully present and subject to removal in the United States. The protections that may be found within a “sanctuary city” are those that are provided for within the push and pull of states’ rights versus federal authority. However, recent actions by the Trump administration such as invoking the Alien Enemies Act of 1798 may mean that federal law enforcement does not need a warrant to search a premises. The 1798 Act grants presidential authority to remove foreign citizens from the United States that have been designated as “alien enemies” in the cases of war or an invasion (Barrett, 2025). The current legal debate is whether the Trump administration can use the act in this way and what the Fourth Amendment implications are, which provides a fundamental protection against “arbitrary arrests.” Sanctuary policies do not necessarily protect individuals from federal “warrantless” arrest or detainment. High profile immigration enforcement seems to be focused on those who engage in criminal activity, leaving room for a misuse of power as the federal government defines just who the “enemy” may be.
Places of religious worship have also historically provided sanctuary to immigrants and refugees. This concept of sanctuary connected to places of worship goes back to ancient Israel, Greece, and Rome, and has history in Medieval Europe (Pillar, 2025). In the United States, churches provided sanctuary to fleeing slaves in the 1800s (Pillar, 2025). During World War II, the Grand Mosque in Paris provided approximately 1,700 French Jewish people with protection and travel assistance (Si Kaddour Benghabrit – Emir-Stein Center, n.d.). In the late 1960’s and early 1970’s in the United States, churches sheltered draft resisters during the Vietnam War (Pillar, 2025). In the 1980s, sanctuary was provided to migrants from Central America (NPR, 2025). The United for Reform Judaism (URJ) encouraged congregations to provide sanctuary to Central American refugees while cautioning "We recognize the serious legal implications of some forms of sanctuary and alert the congregations to the recent prosecutions for assistance and support of these refugees, even as we commit ourselves to support the efforts to overturn the administration's interpretation and application of existing law" (Supporting Immigrants and Refugees in This Challenging Moment, 2024). 2011 guidelines from Immigration and Customs Enforcement established “sensitive locations” such as places of religious worship, schools, and hospitals as areas where ICE actions would not happen. In 2016, churches openly challenged immigration laws during an Obama-era immigration crackdown (Burnett, 2016). However, in January 2025, Acting Department of Homeland Security Secretary Benjamin Huffman rolled back the 2011 guidelines and the 2021 expansion of those restrictions by the Biden administration (Pillar, 2025) As Huffman said, “Criminals will no longer be able to hide in America’s schools and churches to avoid arrest. The Trump Administration will not tie the hands of our brave law enforcement, and instead trusts them to use common sense” (Pillar, 2025). The United States Conference of Catholic Bishops, the Catholic Health Association and Catholic Charities USA issued a joint statement in response, “Non-emergency immigration enforcement in schools, places of worship, social service agencies, healthcare facilities, or other sensitive settings where people receive essential services would be contrary to the common good […] we are already witnessing reticence among immigrants to engage in daily life” (Pillar, 2025). In February 2025, the Institute for Constitutional Advocacy and Protection (ICAP) at Georgetown Law filed a lawsuit on behalf of over two dozen Christian and Jewish religious denominations and associations (Statement on Reform Movement Institutions Joining Major Federal Lawsuit Protecting Religious Freedom, 2025). The federal lawsuit, Mennonite Church USA et al. v. United States Department of Homeland Security et al (2025), challenges the above roll back of the sensitive locations policy restricting ICE from conducting immigration raids, arrests, and other enforcement actions at houses of worship.
While places of worship, like sanctuary states and cities, may not cooperate with federal law enforcement, it would still be illegal for them to interfere with such activity. According to the Church Law Center, “A church can play a role as sanctuary in a wide range of circumstances, including protecting victims of domestic violence, shielding minors from abusers, and simply providing a warm place to sleep during freezing weather. But a church is not, as a general rule, a place where suspected criminals can successfully hide. The law does not prevent police, including immigration enforcement and other specialized units, from entering church grounds to arrest a criminal suspect who has claimed religious sanctuary,” (Church Law Center, 2023). The Baptist Joint Committee provides suggestions for places of worship on how to reimagine what it means to provide “sanctuary.” These include: becoming an established organization to help undocumented persons navigate the immigration system, offering financial and volunteer support for nonprofit organizations who are providing physical or legal assistance to the undocumented community, and getting involved in advocacy efforts on behalf of immigration policies (Baptist Joint Committee for Religious Liberty, n.d.). The Religious Action Center of Reform Judaism also provides information on how to respond if ICE arrives at a temple, reinforcing both the need for a judicial warrant and that they do not participate in immigration enforcement (When ICE Comes to the Congregation Door, 2025). In this way, sanctuary may be interpreted as a place to secure resources, information, and support.
Universities, as one of the “sensitive locations” identified in the 2011 ICE guidelines, also find themselves at a crossroads with federal immigration law enforcement, especially those universities located in sanctuary states. The California State University (CSU) system recently issued guidance to employees regarding the potential for immigration enforcement on its campuses. In the CSU, university police departments (UPD) will not act on the basis of suspected immigration status or to discover immigration status; also, UPD will not join efforts with federal immigration enforcement authorities to investigate, detain or arrest individuals for violation of federal immigration law. However, CSU guidelines indicate that UPD may cooperate with other federal law enforcement entities, such as the FBI, in pursuing suspected criminals or criminal activities on campuses. CSU employee information reinforces that responsibility for the enforcement of federal immigration laws rests with the federal government, and that the California Values Act signed into law in 2017 prohibits state and local law enforcement officers from using taxpayer funds (for example, those designated to the CSU as a state entity) to enforce federal immigration laws (CSU’s Office of General Counsel, n.d.). The University of California (UC) system issued similar guidance. In 2016, the UC issued Principles in Support of Undocumented Members of the University Community and in January 2025 it reaffirmed a commitment to those principles, which, like the CSU, reinforce that the federal government has jurisdiction over enforcement of federal immigration laws, and that UCPD will not, “contact, detain, question, or arrest an individual solely on the basis of suspected undocumented immigration status or to discover the immigration status of any individual, and UC Police will not undertake joint efforts with federal immigration enforcement authorities to investigate, detain or arrest individuals for violation of federal immigration law” (Frequently Asked Questions for University Employees About Possible Federal Immigration Enforcement Actions on University Property, 2025). Both the CSU and the UC offer legal support services related to immigration, as well as open information on their websites: CSU, UC. In contrast to two state school systems located in a sanctuary state, a recent (February 2025) state bill in Tennessee would allow school districts to “opt out” of enrolling students who lack permanent legal status (Wadhwani, 2025). The bill is in direct conflict with a 1982 U.S. Supreme Court decision in Plyler v. Doe (1982), which concluded that excluding children from public schools due to their immigration status was unconstitutional, violating the equal protection clause of the Fourteenth Amendment. This proposed legislation would deny immigrant children without legal permanent status equal access to a public education. In Florida, Gov. Ron DeSantis has said that the state’s universities and colleges shouldn’t admit students lacking permanent legal status (Llanos, 2025). Depending upon the general politics of the state in which they reside, educational institutions may either target undocumented individuals or offer support such as that offered by sanctuary states, cities, or places of worship: not participating with immigration enforcement while providing access to information and resources.
Sanctuary is not as much about protection as it is about having access to resources and a support network. Sanctuary ensures that a robust dialogue around federal and state power continues; it establishes visibility around immigration policies and practices. Places of worship, states, and cities that establish sanctuary policies, and other entities such as educational institutions that provide information and resources, ensure that people are valued above their documentation status.
Glossary
3rd Circuit Court of Appeals - Once the federal district court has decided a case, the case can be appealed to a United States court of appeals. There are twelve federal circuits that divide the country into different regions. The Third Circuit serves the areas of Pennsylvania, New Jersey, Delaware, and the Virgin Islands.
Alien Enemies - An individual who, due to permanent or temporary allegiance to a hostile power, is regarded as an enemy in wartime. During times of war, all natives, citizens, denizens, or subjects of countries with which the United States is at war are deemed by the Federal Government as alien enemies.
Arbiter - Someone with the power to decide a dispute, essentially acting as a judge; an individual or institution that judges and settles quarrels between parties.
Arbitrary - Based on individual discretion or judgment, not based on any objective distinction, and perhaps even made at random; often used to describe a decision or action that is unfair and uses unlimited personal power without considering other people's rights or wishes.
Bill - A formal statement of a proposed new law that is discussed before being voted on.
Coerce - Force
Constitutional Law - The interpretation and implementation of the U.S. Constitution.
Constitutional Interpretation - Involves various methods to understand the meaning of the Constitution as it applies to specific legal and factual circumstances.
Deportation - The process of removing a noncitizen from the U.S. for violating immigration law.
Detainer - A detainer in the context of criminal law is a request filed by a criminal justice agency with the institution in which a prisoner is incarcerated, asking the institution either to hold the prisoner for the agency or to notify the agency when release of the prisoner is imminent. ICE agents can issue a detainer requesting a state or local jurisdiction to hold a suspected non-citizen for an additional 48 hours beyond their scheduled release.
Domain - The territory governed by a single government; realm of responsibility.
Draft Resister - Individual efforts to avoid required military service.
Dual Sovereignty - The concept that two levels of government (usually national and state) coexist and have their own authority over the same territory and population. It allows for a division of powers, where each level has distinct responsibilities. In the United States, the Constitution establishes a system of dual sovereignty, where states have surrendered some powers to the federal government but also retained some sovereignty.
Equal Protection Clause of the Fourteenth Amendment - Refers to the fact that all citizens of the United States are guaranteed equal protection under the laws of the United States. Equal Protection within the fourteenth amendment applies these protections to the individual States.
Executive Order - A directive issued by the President of the United States to manage the operations of the federal government. These orders have the force of law and can be used to direct government agencies and officials in their execution of laws or policies. They remain in effect until they are revoked, amended, or found unconstitutional.
Ideology - A set of beliefs or values attributed to an individual or group, often influencing their actions and decisions.
Judicial Interpretation - The process by which courts interpret and understand the law, particularly constitutional documents and legislation. It involves judges determining the meaning of legal texts and applying them to specific cases.
Jurisdiction - The extent of the power to make legal decisions and judgments; the territory or sphere of activity over which the legal authority of a court or other institution extends.
Legal Challenges - Disputes over the legality or constitutionality of laws, policies, or practices.
Medicaid - A state-administered, federal aid program to help individuals and families with low income obtain health coverage.
Neutral Judge - One who is impartial and unbiased, ensuring that all parties involved in a legal case are treated fairly and have an equal opportunity to present their arguments.
Non-binding - Refers to something that has no legal or binding force; not legally necessary to obey or follow.
Non-compliance - The failure or refusal to comply with established rules, regulations, standards, or obligations.
Probable Cause - Legal justification for a police officer to make an arrest, obtain a warrant, or search a person or property; requires reasonable belief that a crime is being committed or has occurred; determines whether a warrant can be issued or a search conducted.
Ratified - The official approval or acceptance of a proposed treaty, agreement, or law.
Rolled Back - Refers to the act of reversing or reducing the effects of a previous action or decision.
Ruling - An authoritative decision or pronouncement, especially one made by a judge.
Socio-political - Refers to something that is related to both social and political factors, examining the interplay between society and politics, focusing on moral, ethical, and political aspects of human life and interactions.
Sovereign - Refers to a nation or state that has power over itself and is not under the control of an outside authority.
Supreme Court Ruling - A decision made by the highest court in the United States, the Supreme Court, which interprets the Constitution and federal law. These rulings can establish legal precedents, shape public policy, and influence the balance of power among branches of government, as well as between state and federal authorities. Supreme Court rulings are crucial for understanding how judicial interpretations affect individual rights and governmental authority.
Tribunal - Any person or institution with authority to judge, adjudicate on, or determine claims or disputes.
Unconstitutional - Unauthorized by, not allowed by, or inconsistent with the constitution.
Undocumented immigrants - Individuals who were born in a foreign country and who live in the United States with no legal right to.
Warrant - A legal document issued by a judge that authorizes law enforcement officers to carry out a particular action related to the administration of justice (an arrest).
Warrantless Arrest - An arrest of an individual without the use of an arrest warrant.
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