Fighting Trump & Impacts of Sanctuary State Status

Governor Gavin Newsom called for an emergency session to safeguard California’s laws and values before President Trump takes office in January. One of the issues at the forefront of the conversation is our state's status as a sanctuary for undocumented immigrants. But not everyone across California is on board with the Governor’s actions, including one outspoken Sheriff in Southern California.

San Diego Battle Between Policy & Sheriff’s Office

On Tuesday, December 10th, there was a breaking story out of San Diego that the Board of County Supervisors voted to pass an internal policy prohibiting the sheriff’s department from working with U.S. Immigration and Customs Enforcement (ICE). The policy passed in a 3 to 1 decision, with the following statement, “We will not allow our local resources to be used for actions that separate families, harm community trust, or divert critical local resources away from addressing our most pressing challenges.” [1]

The text of the policy argues that for the Sheriff’s office to assist ICE in its efforts is to treat certain individuals differently based solely on their immigration status. It articulates that prohibited activities include informing ICE about illegal immigrants’ incarceration statuses or release dates, allowing ICE to conduct investigative interviews, and responding to ICE’s inquiries.[2] It claims to promote fairness and equal treatment of immigrant communities, and ensure the sustainable allocation of local resources to county matters rather than using funding to assist federal efforts.

This sparked controversy because shortly after the policy was passed, San Diego County Sheriff, Kelly Martinez, came out in opposition to the policy and said she would not comply. She said, “The sheriff's office will not change its practices based on the board resolution and policy that was passed at today's meeting. The Board of Supervisors does not set policy for the Sheriff's Office. The Sheriff, as an independently elected official, sets the policy for the sheriff's office."[3] This is somewhat surprising, given Martinez has identified herself in the past as a Democrat, and the Supervisors who passed the policy are also Democrats. Even though Martinez is not a conservative, she is responsible for maintaining public safety and abiding by state and federal laws. After all, Trump’s newly appointed Border Czar, Tom Homan, has threatened that states and counties that don’t cooperate with ICE could have their federal funding for other public safety programs slashed once the Trump administration takes office.[4]

What’s happening in San Diego is much bigger than just its County Board of Supervisors. The Los Angeles City Council unanimously passed an ordinance on November 19th to establish LA as a sanctuary city and prohibit city resources from being used for help with immigration enforcement as well as prohibit data sharing with ICE.[5] While LA had been declared a sanctuary city back in 2017, this ordinance codifies sanctuary policies into municipal law.[6]

Coalition Against President Trump

These actions by California cities are in direct response to the election results and everything we’ve been hearing from the Trump Administration about working to deport illegal immigrants come Inauguration Day. But it isn’t just cities that are taking action. San Diego and Los Angeles are just following the lead of Governor Gavin Newsom, who called for a special session to prepare the state for Trump’s next term in office. Newsom is asking the Legislature to approve funding for the State’s Department of Justice to fund lawsuits they want to prepare against the Trump Administration. The DOJ has until January 20th to prepare to “safeguard California values.”[7] This reaction also isn’t a surprise, given that during Trump’s first term, California sued the administration so often that it averaged to nearly every 12 days over his four years in office.[8] Newsom’s top priorities are safeguarding California’s legislative stances on abortion, climate change, and, as we see in this story, illegal immigration.[9] California has enacted a series of laws over the past decade that have enshrined it as a “sanctuary state,” meaning that on a statewide level, there are certain restrictions across California for cooperating with immigration authorities. Cities can also enact their own ordinances that take the restrictions further, which is what we’re seeing happen in LA and San Diego.

Current State Law – Sanctuary Status

While the Sheriff of San Diego says her office will not comply with the new policy restrictions, she will still comply with California’s sanctuary status, arguing that the current laws in California strike the appropriate balance between law enforcement in the County and federal immigration authorities. Just what are the laws in place in California? What makes us a sanctuary state?

The TRUST Act

The slippery slope that brought us to where we are today started back in 2013 with the TRUST Act, which stands for the Transparency and Responsibility Using State Tools Act, signed by Governor Jerry Brown. This prohibited state and local law enforcement from detaining illegal immigrants for more than 48 hours on behalf of federal immigration agents, with the exception of those convicted of specific violent or serious crimes.[10] This was because under Obama’s Homeland Security Administration’s “Secure Communities” Program, ICE had visibility into all individuals booked in state and local prisons. So, for those flagged as being in the country illegally, ICE could request local law enforcement to hold them so that ICE could come detain them. The concern of those who opposed this practice was that law enforcement would begin to target illegal immigrants and arrest them just for the sake of detaining them for ICE. They didn’t want to see police officers arresting people on trumped up charges just because they knew they weren’t here legally so that ICE would find out and detain them. They also argued that illegal immigrants who were victims or witnesses of criminal behavior were less likely to come forward out of fear that they would be reported by local law enforcement to ICE. The Trust Act was meant to remedy this by limiting law enforcement’s ability to hold illegal immigrants for ICE, except for those convicted of one of 800 crimes listed out within the Act, including serious crimes like domestic violence abuse and violent felonies.[11]

The TRUTH Act

After the passage and implementation of the TRUST Act, new concerns popped up as ICE no longer asked local law enforcement to hold illegal immigrants for them, but instead began asking for their release dates from state prison or county jail. This way, upon release for whatever crime the individual committed, ICE could show up and detain them on the spot. ICE could also interrogate inmates in prisons to shed light on if they met the standards for deportation. These actions by ICE led Governor Brown to pass the TRUTH Act, which stands for the Transparent Review of Unjust Transfers and Holds Act, in 2016. The TRUTH Act required notification to be given to any person whose release date and time had been requested by ICE. It also required law enforcement to give inmates written consent forms before an ICE interrogation, which they could then either participate in with an attorney present or decline altogether.[12]

This further moved the ball down the field toward restricting cooperation with ICE, as law enforcement shifted to prioritize helping illegal immigrants evade ICE rather than helping ICE detain those in our country, and our state illegally.

The California Values Act (SB 54)

The final blow that made California an outright sanctuary state was the passage of the California Values Act, or Senate Bill 54, in 2017. This was the first time our state was responding to the Trump administration, which created the formula that they’re following now before his second term. Trump took office in January of 2017, then the California Legislature vowed, much as they are doing now, to resist his position on deportation. They introduced SB 54, which would create the most sweeping prohibitions for law enforcement in their interactions with ICE.[13] It essentially prohibited law enforcement from carrying out any immigration enforcement whatsoever.

Listen to just a few of the things the bill prohibited:

1.     Investigation, detainment, and arrest of individuals based on illegal immigration status,

2.     Sharing information about illegal immigrants with ICE,

3.     Assisting immigration authorities with immigration enforcement,

4.     Holding an illegal immigrant in custody to allow immigration authorities to make an arrest, and

5.     Asking about immigration status in routine interactions.[14]

This was super controversial at the time, because the reality was that leading up to Trump taking office, the politicians before him had been pro-deportation. Obama had been dubbed the “Deporter-in-Chief,” given that he deported over 2.5 million illegal immigrants during his two terms in office, more than any other president in history before him.[15] Our current President, Joe Biden, made these comments at a speech he gave in Guatemala as Vice President, “The Department of Justice, Homeland Security…are enhancing the enforcement and removal proceedings because those who are pondering risking their lives to reach the United States should be aware of what awaits them.  It will not be open arms.  It will not be come on -- it will be, we’re going to hold hearings with our judges consistent with international law and American law, and we’re going to send the vast majority of you back.”[16] Nancy Pelosi herself, our representative from San Francisco, supported the Obama administration’s early cooperation with ICE under the Secure Communities Program, saying that our country needed to address the issue of undocumented immigrants, and that “we certainly don’t want more of them coming in.”[17]

Our own Governor, Gavin Newsom, who claims to be such a staunch advocate for the rights of illegal immigrants and the protection of them from ICE – who himself has said he is willing to go to jail rather than work with immigration authorities – has also only recently taken this position. When he was Mayor of San Francisco in 2008, Newsom enacted a city policy to report all undocumented youth to federal immigration authorities like ICE if they were arrested and convicted of a felony. This was radical at the time given that San Francisco had adopted its own sanctuary city law in the late 1980’s. Newsom’s own administration also reported hundreds of undocumented immigrants in the probation system to ICE.[18]

It wasn’t until Trump took office that these politicians began to soften their language around illegal immigration. Because the narrative had previously been that illegal immigration was bad, and that was agreed upon by Democrats and Republicans alike, when Governor Brown signed SB 54 in 2017 to make California the first sanctuary state in the nation, not everyone was on board. In fact, the Los Angeles County Sheriff at the time, Jim McDonnell, opposed SB 54, as he expressed desire to continuing to aide ICE in their removal of undocumented immigrants[19] – especially in a county with one of the largest undocumented populations.[20] Nonetheless, the bill was enacted into law, making California a sanctuary state for illegal immigrants, and hamstringing local law enforcement from assisting with immigration enforcement.

It is, therefore, no surprise, that as we face another Trump term, our Legislature is gearing up for another fight over immigration and is digging in their heels to protect our “sanctuary state” status.

Real-Life Impacts of Sanctuary State Status

It’s important to understand acts like the TRUST Act and SB 54 because California is home to 23% of all immigrants in the United States. As of 2022, we had 10.4 million immigrants, which is the highest share of any state. It’s important to note that only 54% of these immigrants are naturalized US Citizens. It’s hard to pinpoint just how many are illegal immigrants, given that law enforcement can’t report on it, but the Public Policy Institute of California estimates in 2021 that 1.85 million immigrants were undocumented.[21] It’s fair to wonder how much larger that number is in recent years, given the over 8 million migrant encounters at the border and the 1.7 million known gotaways who evaded border security under the Biden Administration.[22]

The 2023 State of Immigrants in LA County (SOILA) Report found that in LA County alone, there are 3.5 million immigrants, 800,000 of whom are estimated to be undocumented.[23] That breaks down to mean that 34% of our county’s population is immigrants, and 23% of those immigrants are undocumented. Other counties that are home to large shares of California’s immigrant population are Santa Clara, San Mateo, Alameda, and San Francisco.[24]

But just how has housing and protecting undocumented immigrants via our sanctuary state laws worked out for us? While one could argue that our immigrant communities bring great diversity and cultural variety to our state, there is also a distinction between legal immigrants and illegal immigrants. Overlooking and even protecting large numbers of people who are in our country and our state illegally has had negative impacts on more than one occasion, which makes sense when you consider that undocumented immigrants have already broken the law just by living here illegally.

Just a few weeks ago, the Mayor of Newport Beach expressed his frustration with the state’s prohibition on immigration enforcement when a boat carrying 21 migrants trying to enter the US illegally was stopped by the US Coast Guard just one mile from Newport Beach. The migrants were mostly Mexican nationals, except for two Uzbekistan nationals and one Russian national.[25] This isn’t a new occurrence, as this happened back in April as well, except that time the migrants were successful in exiting the boat and escaping in a waiting vehicle. The same thing also happened back in December, this time in Malibu, when a Panga boat full of migrants was caught on video arriving on shore without intervention. Panga boats are known to be used by human and drug smugglers.[26]

In an in-depth investigation conducted by the San Francisco Chronicle, Honduran drug dealers told reporters that San Francisco is a hotbed for drug dealing because of the city’s sanctuary state laws. “The reason is because in San Francisco, it’s like you’re in Honduras. Many look for San Francisco because it’s a sanctuary city…because they don’t deport. You go to jail and you come out.”[27] Successful dealers report earning $350,000 per year off the death of thousands in our cities. As a result, a member of the San Francisco Board of Supervisors proposed withdrawing sanctuary city protections for those trafficking drugs like fentanyl.[28] Nothing changed, as the Board voted to keep the policies the same as they are, and even criticized the member who proposed a change in the first place.[29]

The Los Angeles Police Department reported this year that South American gangs have infiltrated neighborhoods to commit theft. One gang from Chile conducted bank heists across California and made off with $2.5 million dollars.[30] Others target wealthy homes, using jamming devices to disable home security systems and building an organized burglary ring. In March, LAPD Chief, Dominic Choi, put it this way, “I can tell you that we have a significant increase in burglaries from organized groups that are outside this country, that are coming into the country, and they are targeting high-end residents.”[31] These groups don’t just come from Chile, but from plenty of other South American countries as well, including Preu, Ecuador, and Colombia. Deputy Chief Alan Hamilton confirmed that while crime statistics report a decline in burglaries, “The number of crimes tied to these kinds of crews are way, way up.”[32]

And for those who say, well Los Angeles is a big city, its particularly dangerous and attracts criminals, this isn’t happening in LA proper. This is happening in the suburbs. In fact, in one city that’s an hour away from the city, so not LA proper by any means, residents reported multiple break-ins that were tied back to these South American gangs, and even noticed drones flying around their neighborhoods and above their homes. Some residents followed these drones and found the gang members congregating at a local hotel, where they all appeared to be staying.[33]

Illegal immigration has exposed our state, and many other states across our country to some of the worst criminals. You may have heard by now of the famous Tren De Aragua, which is a transnational gang that started in Venezuelan prisons and has been reported to be within the United States in recent months. If you heard of the Colorado apartment buildings that were taken over by gangs, or the murder of 12-year-old Jocelyn Nungaray in Texas, then you already know the violent and brazen crime the gang has been committing throughout the country. It is reported that Tren De Aragua is in California as well, as the Department of Homeland Security has been tracking gang members and warning states as they locate them.[34]

Does all this sound like our sanctuary state policies were such a great idea after all?

Response

What history and common sense have shown us is that overlooking illegal immigration is our government’s abdication of its responsibility to protect its own citizens first. This abdication has only led to chaos, violence, and crime.

Where do I get the idea that government has the responsibility to protect its citizens? Well, one trustworthy source is our very Constitution. Article IV, Section 4 states, “The United States shall guarantee to every state in this union a republican form of government and shall protect each of them against invasion.”[35] The Framers saw that the government had the fundamental responsibility to protect its states, and thereby its citizens, from foreign invasion by providing a common defense. There is much debate over what the word invasion really means, and what our Founders intended in writing it. It does not seem to limit itself, implying any unwanted unlawful entry into our country that threatens the interests of a state and therefore its citizens.[36] While some say that invasion only relates to invasion by another country, such as war with Britain, but other texts that expound upon the Constitution, such as the Federalist Papers, seem to support the idea that the Framers were aware that our country faced many different external threats, and would continue to face new threats, especially from our neighbors, at our borders.

Listen to how Alexander Hamilton explained the need for common defense in Federalist Paper 25 all the way back in 1787:

“The territories of Britain, Spain, and of the Indian nations in our neighborhood do not border on particular States but encircle the Union from Maine to Georgia. The danger, though in different degrees, is therefore common. And the means of guarding against it ought, in like manner, to be the objects of common councils and of a common treasury. It happens that some States, from local situation, are more directly exposed.”[37]

He describes the dangers that are bordering their new nation – dangers of foreign governments, like Britain and Spain, but also local threats like the Indian nations. The word invasion is not limited just to the specific threats the Founding Fathers could see in front of them at the time, but any threat to the safety of our nation and its people by different groups who are identified as NOT being part of our nation. We can apply this today to include threats of foreign “drug traffickers, gang members, other violent criminals, as well as suspected terrorists”[38] who are pouring across our border illegally and entering our communities.

This idea is also just common sense. If a country does not protect its own people, then it isn’t a country. The entire point of defending our borders and our sovereignty is not to keep out legal immigrants; the point is that when you live in a country, you are a part of that country and its culture, and you are subject to its laws and customs. What makes America unique is that it is made up of Americans, in the same way that every other country has its own people. This is true of every other country on the planet. Every other country has its own citizens, its own languages, its own people. America is no different. The primary job of a country’s government is to protect and defend its citizens.

This doesn’t have to mean that we accept zero immigrants, or that we view people from other countries in a way that is evil, racist, or unloving. What it does mean is that when we do accept people into out country to live here permanently, we require that they go through the legal process in order to vet their background and criminal history, we ensure that they are committed to abiding by the laws and customs that we have in this country, and we are confident that they will not negatively impact our communities through crime or violence. Those processes for legal immigration here are in place, and the United States is ranked as the country that takes in the most immigrants, above Germany, the UK, Spain, and Canada.[39] America is incredibly welcoming to the foreigner, but the responsibility of our government to protect its people means that it is only welcoming insofar as the foreigner is not posing threat to its people. When a government allows mass illegal immigration, it can no longer say it has assurance that the people its welcoming won’t harm its citizens, because it just doesn’t know. It hasn’t vetted them. It is abandoning its primary responsibility, and it is ignoring our Constitution’s charge to protect from invasion.

State Defiance of Federal Law

Is it right, then, for California to refuse to cooperate with the federal government in immigration enforcement? Title 8, Section 1324 of the United States Code (8 U.S.C. § 1324), which is the Federal Criminal Code, establishes that it is a felony to knowingly harbor, shield, or hire illegal immigrants, and each action brings with it a sentence of jail time per instance.[40] Doesn’t it seem like California is knowingly harboring and shielding illegal immigrants?

Sanctuary state laws have been allowed under the theory that law enforcement does not prevent or impede immigration authorities; it just doesn’t help them carry out their duties. The law doesn’t mandate that law enforcement volunteers information, and so these cities, and our state, isn’t breaking any law, it just isn’t enforcing immigration law. Opponents, like the California State Sheriffs’ Association, argue that the main problem with sanctuary laws is the confusion they cause for both law-enforcement officers and business owners.[41] After all, if the state knows illegal immigrants are living here, and they even claim that they are an integral part of our cultures and communities, then what is the expectation for where they will work? The federal government says it’s illegal to hire undocumented immigrants, but the state acknowledges that they live and work here, so which it?

What’s interesting though is the shift that has happened in sanctuary states and cities over the years. I could easily agree that the TRUST Act and even the TRUTH Act did not impede the abilities of ICE to carry out immigration enforcement. But the culture today has moved so far the opposite direction that it has moved to the side of stopping immigration authorities entirely. Mayor of Denver Colorado, Mike Johnston, has expressed a willingness to go to jail in order to protect undocumented immigrants from ICE authorities.[42] J.B. Pritzker, Governor of Illinois, has made the same pledge, threatening the Trump Administration that, “If you come for my people, you come for me.”[43] New York Senator, Jessica Ramos, criticized New York’s Mayor Eric Adams for meeting with the Trump Administration on immigration reform, saying that assisting with immigration enforcement makes him an “accomplice.”[44] And of course, our beloved Governor, Gavin Newsom, publicly sparred with Attorney General Jeff Sessions during his run for Governor in 2018, vowing that he would go to jail to protect illegal immigrations from ICE.[45]

This is the danger of sanctuary laws – when they are used as a weapon to disregard immigration authorities, or to prevent them from doing their jobs entirely. One prime example of how radical the leaders of states like California has become is Libby Schaaf, who was Oakland’s Mayor from 2015 to 2023. In 2018, Schaaf announced an impending ICE raid during a press conference. She said, “I am sharing this information publicly not to panic our residents but to protect them.... My priority is for the well-being and safety of all residents—particularly our most vulnerable.”[46] ICE arrested 232 illegal immigrants, over half of whom had criminal records. They reported that 864 illegal immigrants had evaded the raid due to her warning, all with criminal records.[47] Schaaf defended her actions, saying she had a moral and ethical duty to warn the community that ICE would be making arrests. She too said that she was willing to go to jail to protect undocumented immigrants, and that she considered herself a part of a resistance movement against the President’s Administration.[48] Gavin Newsom praised her actions and bragged about her defiance of the law.[49]

This mentality clearly moves far past just not assisting immigration enforcement. This is direct defiance of federal law. This is legally wrong, and it’s morally wrong. Schaaf clearly stated that her priority was for the well-being of illegal immigrants – most of whom were criminals. That is not the job of our elected representatives. They have been charged with the primary responsibility of prioritizing the well-being of their citizens, not those who have infiltrated communities illegally and have committed rampant crime, victimizing law-abiding citizens. It is not right for our state to take this stance, and it is not right for our state to impose this on every local government.

If San Diego’s Sheriff acknowledges her duty to allow immigration enforcement and sees that the good of her community would be promoted by enforcing the law, she should not be prevented by the state from carrying that duty out and complying with federal law.

Protection of Illegal Immigrants

The last point I want to address is the idea that to love our neighbor, or to love the foreigner, we have to support illegal immigration. After all, there are many undocumented immigrants who are normal people, who are not criminals, who build their lives here and simply desire the better life that America offers them. Does it make us unloving as Christians to support deportation efforts? Does love mean we accept all people into our country?

The answer is no. Public policy is a balance of interests. The government has to consider who it has a duty to prioritize. Obviously, this means that the government must prioritize its own citizens over criminals, because criminals clearly are a danger and have forfeited any case for living here. But it also means that the government has to prioritize its own citizens over people who are not its citizens. This means that both the federal and state governments have an interest in their own people first, even before good people from other countries. Public policy is built on these interests. This isn’t unloving, this is what it means to be a country. Again, our country welcomes immigrants from other countries, over and above the immigration efforts of all other countries. But it has to do so in a systematic way that looks first to the interests of its own people. No one has a fundamental right to come to America, in the same way that no one has a fundamental right to become a citizen of India, or the UK, or Ireland. Each country sets immigration policy to determine how many immigrants it can welcome and support each year, how mass immigration will affect the lives, jobs, and resources available to its citizens, and how immigration will change the culture and values of the country as a whole.

If public policy said, “we don’t welcome anyone to America who is Asian because Asians are inferior and do not deserve entry into our country,” then that would be discriminatory and unjust. But if public policy says we have a process in place for immigrating to our country, we have limits on how many people we can support from each country each year, and we have to consider total impact to our country, that is a wise and fair approach.

In the Bible, when God calls Israel to love the foreigner, this wasn’t a call for unfettered illegal immigration. Exodus 12 outlines the laws that the foreigner must follow, and the customs they must adopt. The foreigner had duties and responsibilities. Allie Beth Stuckey puts it this way:

“God wasn’t condoning uncontrolled immigration, but rather the orderly acceptance of people willing to observe Jewish practices and to assimilate into Jewish culture. Reciprocity and respect were requisite. Israel had to respect foreigners and treat them with dignity, but foreigners had to do the same to the nation of Israel, and they could not respect Israel without respecting its laws.”[50]

That sounds a lot like legal immigration today, doesn’t it? We can respect immigrants, and even welcome them, but only when they respect our laws, which require they come here through the legal process, not through illegal means.

Takeaways

So, as you see more and more headlines like these in the news, and as you see our state begin to fight the Trump administration’s immigration policies in the months to come, do not be deceived. Do not accept the lie that illegal immigration is loving. Be informed and equipped to fight the narrative and to push forward truth-filled values and ideals. Love your neighbor by seeking their good through upholding order, not chaos or crime. And lastly, implore our state representatives to spend less of their time preemptively fighting Trump and more of their time putting the safety and protection of their own citizens first.

References:

[1] Associated Press. “San Diego Sheriff Defies New Policy to Limit Cooperation With Immigration Officials.” US News, December 10, 2024. https://www.usnews.com/news/politics/articles/2024-12-10/san-diego-raises-bar-to-work-with-immigration-officials-ahead-of-trumps-deportation-efforts.

[2] Vargas, Nora. “ADOPTING A BOARD POLICY ON IMMIGRATION ENFORCEMENT TO ENHANCE COMMUNITY SAFETY (DISTRICTS: ALL).” Sandiegocounty.Gov. San Diego County Board of Supervisors, December 10, 2024. https://bosagenda.sandiegocounty.gov/cobservice/cosd/cob/content?id=0901127e8113b0a1.

[3] Shaw, Adam, and Bill Melugin. “Border Sheriff Ignores County’s New Policy That Blocks Cooperation With ICE Immigration Enforcement.” Fox News, December 11, 2024. https://www.foxnews.com/politics/border-sheriff-ignores-countys-new-policy-blocks-cooperation-ice-immigration-enforcement.

[4] Debusmann, Bernd, Jr. “Will Trump’s ‘Border Tsar’ Slash Funding to ‘Sanctuary’ States?” BBC News, November 25, 2024. https://www.bbc.com/news/articles/cdxv0ey94gxo.

[5] Debusmann, Bernd, Jr. “Los Angeles Declares Itself An Immigration ‘Sanctuary.’” BBC News, November 20, 2024. https://www.bbc.com/news/articles/c4gx7rd4nj7o.

[6] Los Angeles City Councilmember 4th District. “City Council Votes to Establish Los Angeles as a ‘Sanctuary City.’” CD4.LACity.gov, November 19, 2024. https://cd4.lacity.gov/press-releases/city-council-votes-to-establish-los-angeles-as-a-sanctuary-city/#:~:text=City%20Council%20Votes%20To%20Establish%20Los%20Angeles%20As%20A%20'Sanctuary%20City',-For%20Immediate%20Release&text=Today%2C%20the%20Los%20Angeles%20City,utilized%20for%20any%20immigration%20enforcement.

[7] Koseff, Alexei, and Jeanne Kuang. “Newsom Calls Special Session to ‘Trump-proof’ California.” CalMatters, November 8, 2024. https://calmatters.org/politics/capitol/2024/11/gavin-newsom-special-session-trump-resistance/.

[8] Ibarra, Ana B., and Nigel Duara. “California Beat Trump in Court His First Term. It’S Preparing New Cases for His Second.” CalMatters, November 8, 2024. https://calmatters.org/justice/2024/11/california-vs-trump-lawsuits/.

[9] Koseff and Kuang, “Newsom Calls Special Session to ‘Trump-Proof’ California.”

[10] Ulloa, Jazmine. “How California’s Trust Act Shaped the Debate on the New ‘sanctuary State’ Proposal - Los Angeles Times.” Los Angeles Times, November 19, 2017. https://www.latimes.com/politics/la-pol-ca-trust-act-sanctuary-state-immigration-20170910-htmlstory.html.

[11] Ibid.

[12] Lee, Olivia. “California’s TRUTH Act – Due Process for Immigrants Held in Local Jails.” American Immigration Lawyers Association, October 26, 2016. https://www.aila.org/blog/californias-truth-act-due-process-for-immigrants-held-in-local-jails#:~:text=California's%20TRUTH%20Act%20%E2%80%93%20Due%20Process%20for%20Immigrants%20Held%20in%20Local%20Jails,-10%2F26%2F16&text=On%20September%2028%2C%202016%2C%20California,against%20harsh%20immigration%20enforcement%20practices.

[13] Galeano, Christopher A. “Senate Bill 54 (2017): California Versus the Law Enforcement Lobby.” UCLA Law Review, March 4, 2022. https://www.uclalawreview.org/senate-bill-54-2017-california-versus-the-law-enforcement-lobby/.

[14] California Legislative Information, “Bill Text - SB-54 Law Enforcement: Sharing Data.,” October 5, 2017, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB54.

[15] ABC News. “Obama Has Deported More People Than Any Other President,” October 20, 2016. https://abcnews.go.com/Politics/obamas-deportation-policy-numbers/story?id=41715661.

[16] Biden, Joseph. “Remarks to the Press With Q&A by Vice President Joe Biden in Guatemala.” Whitehouse.Gov. Guatemala City, Guatemala, June 20, 2014. https://obamawhitehouse.archives.gov/the-press-office/2014/06/20/remarks-press-qa-vice-president-joe-biden-guatemala.

[17] C-Span. “User Clip: 2008 Nancy Pelosi Secure the Border.” C-SPAN.Org, February 8, 2018. https://www.c-span.org/clip/news-conference/user-clip-2008-nancy-pelosi-secure-the-border/4713577.

[18] Tolan, Casey. “As Mayor, Newsom Policy Reported Undocumented Youth to ICE.” Daily News, March 20, 2018. https://www.dailynews.com/2018/03/20/as-mayor-newsom-policy-reported-undocumented-youth-to-ice/.

[19] Galeano, “Senate Bill 54 (2017): California Versus the Law Enforcement Lobby.”

[20] Gillette, Gabrielle, Victoria Ivie, and Gqlshare. “Latest ‘State of Immigrants’ Report Reveals Ongoing Barriers for LA County’s Fastest-growing Group.” Daily News, July 15, 2024. https://www.dailynews.com/2024/07/13/latest-state-of-immigrants-report-reveals-ongoing-barriers-for-l-a-countys-fastest-growing-group/.

[21] Cuellar Mejia, Marisol, Cesar Alesi Perez, and Hans Johnson. “Immigrants in California.” The Public Policy Institute of California, January 2024. https://www.ppic.org/publication/immigrants-in-california/.

[22] House Committee on Oversight and Accountability and House Committee on Homeland Security, “Crisis at the Border: Reports From the Frontline,” Report, House Oversight and Homeland’s Report, 2023, https://budget.house.gov/imo/media/doc/ogr_icymi.pdf.

[23] Gillette, Ivie, and Gqlshare, “Latest ‘State of Immigrants’ Report Reveals Ongoing Barriers for LA County’s Fastest-Growing Group.”

[24] Cuellar Mejia, Alesi Perez, and Johnson, “Immigrants in California.”

[25] Asperin, Alexa Mae. “Newport Beach Mayor Rips California’s Sanctuary State Policy After 21 Migrants Detained on Boat.” FOX 11 Los Angeles, November 18, 2024. https://www.foxla.com/news/newport-beach-mayor-california-sanctuary-state-policy-migrants-detained-boat.

[26] Fox 11 Digital Team. “Video Shows Panga Boat Filled With Suspected Illegal Immigrants Land on Malibu Coast.” FOX 11 Los Angeles, December 1, 2023. https://www.foxla.com/news/malibu-panga-boat-suspected-illegal-immigrants.

[27] Downey, Caroline. “Honduran Drug Dealers Say They’ve Flocked to San Francisco Because of Sanctuary Laws.” National Review, July 10, 2023. https://www.nationalreview.com/news/honduran-drug-dealers-say-theyve-flocked-to-san-francisco-because-of-sanctuary-laws/.

[28] Ibid.

[29] Stinson, Sara. “KRON4.” KRON4, March 8, 2023. https://www.kron4.com/news/bay-area/san-francisco-supervisors-vote-to-uphold-sanctuary-policy/.

[30] Solis, Nathan. “South American Crew Used Signal Jammers, Disguises on Heists, Feds Say - Los Angeles Times.” Los Angeles Times, November 5, 2024. https://www.latimes.com/california/story/2024-10-29/south-american-bank-heist-crew-california-crime-spree.

[31] Winton, Richard. “Sophisticated ‘burglary Tourists’ Fly From South America to Rob Wealthy Homes, LAPD Says - Los Angeles Times.” Los Angeles Times, March 18, 2024. https://www.latimes.com/california/story/2024-03-16/los-angeles-police-south-american-crime-tourism.

[32] Ibid.

[33] Guzman, Alyssa. “Wealthy West Coast Suburb Is Living in Fear as South American Gang Uses Sinister Tech to Track Their...” Mail Online, November 23, 2024. https://www.dailymail.co.uk/news/article-14117763/west-coast-suburb-south-american-gang-sinister-technology.html.

[34] Romo, Rafael, Belissa Morillo, and Laura Weffer. “This Is the Dangerous Venezuelan Gang Infiltrating the US That You Probably Know Nothing About but Should.” CNN, June 10, 2024. https://www.cnn.com/2024/06/09/us/tren-de-aragua-venezuela-gang/index.html.

[35] National Constitution Center – constitutioncenter.org. “The 4th Article of the U.S. Constitution,” n.d. https://constitutioncenter.org/the-constitution/articles/article-iv#article-section-4.

[36] Center for Renewing America Staff. “The Federal Government’s Guarantee to Protect the States Against Invasion.” The Center for Renewing America, February 1, 2024. https://americarenewing.com/issues/the-federal-governments-guarantee-to-protect-the-states-against-invasion/#:~:text=The%20Guarantee%20Covers%20All%20Invasions&text=The%20full%20and%20fair%20scope,invaded%20and%20the%20citizens%20therein.

[37] Hamilton, Alexander. “The Powers Necessary to the Common Defense Further Considered.” The Federalist Papers. December 21, 1787, 25 edition. https://avalon.law.yale.edu/18th_century/fed25.asp.

[38] Center for Renewing America Staff, “The Federal Government’s Guarantee to Protect the States Against Invasion.”

[39] Davis, Elliot, Jr. “10 OECD Countries With the Most Migrants.” US News, February 21, 2024. https://www.usnews.com/news/best-countries/slideshows/10-countries-that-take-the-most-immigrants?slide=7.

[40] Eisner Gorin LLP. “Title 8 U.S. Code § 1324 - Bringing in and Harboring Aliens.” The Federal Criminal Attorneys, n.d. https://www.thefederalcriminalattorneys.com/harboring-aliens#:~:text=What%20Are%20the%20Penalties%20for,up%20to%20life%20in%20prison.

[41] Gorn, David. “Rebelling Against California’s Sanctuary Law—from Inside California.” CalMatters, June 23, 2020. https://calmatters.org/justice/2018/05/rebelling-against-californias-sanctuary-law-from-inside-california/.

[42] Harris, Kyle. “How Denver’s Mayor Is Responding to Trump’s Threats to Defund Sanctuary Cities.” Denverite, November 22, 2024. https://denverite.com/2024/11/20/denver-immigration-policies-donald-trump/.

[43] Flosi, Nic. “Trump’s ICE Chief to Pritzker: ‘Game on’ in Immigration Policy Clash, Vows Enforcement.” FOX 32 Chicago, November 13, 2024. https://www.fox32chicago.com/news/tom-homan-jb-pritzker-immigration-vows-enforcement.

[44] O’Brien, Shane. “State Sen. Ramos Slams Mayor Adams for Meeting With Trump’s Border Czar, Warns of Harm to Immigrant Communities.” Jackson Heights Post, December 13, 2024. https://jacksonheightspost.com/ramos-criticizes-adams-trump-border-czar.

[45] Tolan, “As Mayor, Newsom Policy Reported Undocumented Youth to ICE.”

[46] Santa Clara University. “A Mayor’s Announcement About ICE Raids and the Practice of Ethical Leadership.” Markkula Center for Applied Ethics, May 7, 2018. https://www.scu.edu/leadership-ethics/resources/a-mayors-announcement-about-ice-raids-and-the-practice-of-ethical-leadership/.

[47] Ibid.

[48] Flynn, Meagan. “Oakland Mayor Libby Schaaf Tipped off Immigrants About ICE Raid and Isn’t Sorry She Did.” The Washington Post, February 28, 2018. https://www.washingtonpost.com/news/morning-mix/wp/2018/02/28/oakland-mayor-libby-schaaf-tipped-off-immigrants-about-ice-raid-and-isnt-sorry-she-did/.

[49] Garofoli, Joe. “Candidate Gavin Newsom Uses Insult by Jeff Sessions as a Fundraising Tool.” San Francisco Chronicle, March 8, 2018. https://www.sfchronicle.com/politics/article/Candidate-Newsom-uses-insult-by-Jeff-Sessions-as-12736707.php.

[50] Allie Beth Stuckey, Toxic Empathy: How Progressives Exploit Christian Compassion, vol. Pg. 122 (Penguin Group, 2024).