By Sean Davis
Co-Founder and CEO, The Federalist

The following is adapted from a speech delivered on June 19, 2026, aboard the Silversea Silver Dawn, during a Hillsdale educational cruise through the fjords of Norway.

On July 1, 2015, 32-year-old Kathryn “Kate” Steinle was killed while sightseeing in San Francisco with her father and a family friend. According to federal prosecutors, Steinle was walking on Pier 14, a popular tourist attraction in San Francisco’s Embarcadero area, when she was shot in the back by Jose Inez Garcia-Zarate, an illegal immigrant from Mexico with a lengthy criminal record.

It wasn’t Garcia-Zarate’s first illegal trip into the U.S. Federal immigration records show that he had been deported six times prior to Steinle’s killing: in 1994, 1997, twice in 1998, 2006, and 2009. And he had been arrested by San Francisco police in March 2015, four months before the murder, for an outstanding drug possession warrant.

Following his arrest, U.S. immigration officials lodged an immigration detainer on Garcia-Zarate — in other words, they requested that the police hold him for an additional 48 hours to allow them time to assume custody and deport him. Instead, San Francisco’s prosecutor, George Gascón, dropped the drug charges and the San Francisco police, as a matter of policy, disregarded the federal immigration detainer and released Garcia-Zarate on April 15. Less than three months later, Kate Steinle was dead.

Although it seems impossible, the story gets worse. Garcia-Zarate claimed that he had accidentally picked up and fired the pistol that killed Steinle, and a San Francisco jury found him innocent of murder. He was convicted on a minor charge of illegal possession of a firearm, but not even that held up. In 2019, a California appeals court tossed the conviction on the grounds that if Garcia-Zarate had only held the gun for a little while — even if it was just barely long enough to shoot and kill an innocent woman — the jury should have been given the option to acquit him on the grounds that he didn’t technically possess it. In the end, Garcia-Zarate was simply deported in 2024 — three decades after his first of seven illegal incursions into the U.S. and nearly nine years after he killed Kate Steinle.

Such is life, death, and injustice in a so-called sanctuary city like San Francisco and a sanctuary state like California. How could this happen? How could a foreign national repeatedly enter our country, violate our laws, kill one of our fellow citizens, and never be held accountable? To answer this question, you have to understand the nature of the sanctuary movement in America and the threat it poses to the safety and security of Americans and to the rule of law.

Where does the word “sanctuary” come from? The Oxford English Dictionary tells us its first use in English dates back to the mid-14th century writings of Richard Rolle, a Christian hermit who translated large swathes of the Latin translation of the Old Testament into Old English and provided commentary on them. Rolle’s first use of the word in English unsurprisingly corresponds with the first use of the word in the Bible, in Exodus 15, when Moses praises the Lord for redeeming His people from Pharaoh and delivering them to safety: “You will bring [your people] in and plant them on your own mountain / the place, O Lord, which you have made for your abode / the sanctuary, O Lord, which your hands have established.”

In this context, sanctuary refers to a holy place where the Lord resides. It can also be a place of refuge. Following the exodus from Egypt, for example, God commanded His people to establish “cities of refuge” where those suspected of unintentional manslaughter could flee while awaiting trial. Murderers, on the other hand — those who killed intentionally out of enmity — were given no quarter.

If a man accused of manslaughter was tried by the people of the city where he sought refuge and was found guilty of murder, then he was to be punished for murder. If he was found to have committed manslaughter, he would be spared, but only as long as he remained in the city of refuge.

One sees in this arrangement the balance between justice and mercy, the benefits of separating victims and perpetrators in cases of accidental deaths, and the practical wisdom of preventing cycles of violence and retribution between aggrieved parties in close contact with one another. Avengers are not given carte blanche to wreak vengeance. Nor are perpetrators allowed to continue on as if nothing happened. Even the interplay between the words “refuge” and “fugitive,” which share the same root, suggests that the goal of the original sanctuary city was not a permanent escape from the consequences of criminal behavior but rather justice in accordance with the law.

The American sanctuary movement, by contrast, rewards criminality and endangers innocent citizens. Its history began in 1971 in Berkeley, California, at the height of the anti-Vietnam protests, when city officials passed a resolution declaring Berkeley a “City of Refuge” for draft dodgers. Eleven years later, Gus Schultz, a left-wing Berkeley pastor, expanded the idea by declaring his church a safe harbor for asylum seekers fleeing El Salvador, Honduras, and Guatemala.

In early 1985, the city of Berkeley passed the following resolution:

BE IT FURTHER RESOLVED that no employee of the City of Berkeley violate the established sanctuaries by assisting in investigations, public or clandestine, by engaging in or assisting with arrests for alleged violation of immigration laws by the refugees in the sanctuaries or by those offering sanctuary, or by refusing established public services to the established sanctuaries.

City councilors further resolved that the “sanctuary originally offered by the churches be expanded to include the entire city and that BERKELEY become a CITY OF REFUGE[.]” San Francisco, across the bay from Berkeley, followed suit in 1989, and the sanctuary city concept quickly spread across the country to Tucson, Seattle, Duluth, and Ithaca.

The actions of those offering sanctuary at the time violated U.S. immigration law, because the asylum claims being made by Latin American refugees were in almost every case rejected during the Reagan administration. The reasoning was that if the migrants were, as they claimed, fleeing violence in their home countries, they could flee to the nearest safe country — whether Mexico to the north or Venezuela or Colombia to the south — rather than to the U.S. Because they were not seeking refuge in the nearest safe country, they were determined by the U.S. government to be economic migrants, seeking economic opportunities in our country, rather than war refugees seeking an escape from violence. As such, they did not qualify for asylum.

Fast forward to 2021, when the Biden administration threw federal immigration law out the window. In effect, under the guise of granting asylum, it federalized and supercharged the sanctuary city efforts that began in the 1980s, erasing the border and inviting anyone into the U.S. who wished to come.

The U.S. Customs and Border Patrol estimated there were more than eight million encounters along the U.S.-Mexico border during the Biden years, with some estimates north of ten million. Migrants arrived from all over Latin America, often with the aid of drug cartel coyotes who were either paid by the job or expected services to be rendered once their charges reached the U.S. Coached by lawyers from so-called non-governmental organizations (NGOs) to make asylum claims, they were then released into the U.S. on their own recognizance and told to appear in court years later to have their asylum claims adjudicated. The Biden administration even arranged to have many of them flown — at the American taxpayer’s expense — to cities of their choice.

Thus what had started as a narrow effort to take care of a small number of needy refugees in a single city developed, after several decades, into a sprawling global industry involving national governments, NGOs, criminal syndicates, and hundreds of billions of American taxpayer dollars a year. Every institution involved had either a political or an economic incentive to ensure a never-ending flow of migrants into the U.S. Forget vetting. Forget filtering out criminals and drug traffickers. Forget ensuring that only those willing to assimilate into our culture should be admitted into our country. The illegal immigration-industrial complex had become a self-perpetuating machine.

Over the past year-and-a-half, the second Trump administration has reestablished secure borders — without which a country can hardly claim to be a country — and has attempted to begin deporting those who entered illegally during the previous four years. But its efforts have been met at every turn with opposition, often violent, even when it comes to deporting the most dangerous illegal immigrants. And much of this opposition is sanctioned by state and city officials enlisted in the sanctuary movement.

As of last year, the U.S. Department of Justice calculated that twelve states and the District of Columbia — nearly one-quarter of the country — had become sanctuaries for illegal immigration. In addition, many major cities outside of those states — including Albuquerque, Boston, New Orleans, Newark, and Philadelphia — had been designated as sanctuary cities. The Center for Immigration Studies counts the number of sanctuary cities or counties across the country at more than 200.

In a healthy country, the American experiment with the sanctuary movement would be widely recognized as a deadly failure. Sadly, stories like that of Kate Steinle have become commonplace. Not only does the sanctuary movement foment and incentivize illegal immigration, it also shields known violent predators from justice.

Philadelphia formally adopted sanctuary city policies in 2014. That same year, Juan Ramon-Vasquez, an illegal immigrant from Honduras who had been deported five years earlier, was taken into custody by the Philadelphia Department of Prisons. U.S. Immigration and Customs Enforcement (ICE) attempted to remove him, but he was shielded from deportation by local officials and released from jail, after which he went on to rape a young child repeatedly over a period of 18 months. “If the ICE detainer had been honored by local law enforcement,” said U.S. Attorney William McSwain,

this crime never would have happened, and the victim — an innocent child — would have been spared horrendous physical and mental trauma. Criminals like Ramon-Vasquez take note: my office will do everything in its power to find you, to protect our community, and to seek justice for your victims. Unlike the Philadelphia government, we are not on your side.

On February 27, 2024, Laken Riley, a 22-year-old nursing student at Augusta University in Athens, Georgia, went out for a jog and was abducted and brutally murdered by Jose Antonio Ibarra, an illegal immigrant from Venezuela with ties to the Tren de Aragua terrorist cartel. Ibarra had been caught illegally entering the U.S. near El Paso in 2022 but was released into the U.S. as part of the official policy of the Biden administration. He found his way to New York City where, according to The New York Times, he was put up at the Crowne Plaza hotel in Queens. He eventually made his way to a city-run migrant center at the Roosevelt Hotel in Manhattan and requested to be flown to Georgia, where his brother had told him he could find better work. U.S. taxpayers paid for his flight from New York to Georgia, and less than five months later, Laken Riley was dead.

On June 16, 2024, twelve-year-old Jocelyn Nungaray was kidnapped, sexually assaulted, and strangled to death in Houston, Texas. Two illegal immigrants from Venezuela, Johan Jose Martinez-Rangel and Franklin Jose Pena Ramos, are awaiting trial for these crimes. U.S. Border Patrol had apprehended Martinez-Rangel three months before Nungaray’s murder and Ramos less than a month before her murder. As part of the official policy of the Biden administration, rather than being deported, they were released into the U.S. with a notice to appear in court at a later date.

In Virginia in 2025, federal immigration authorities were able to detain and remove from the U.S. an illegal immigrant named Edwin Antonio Hernandez. A violent MS-13 gang member from El Salvador, Hernandez had entered the U.S. in 2015 at the age of 16. Arrested by Border Patrol in 2017, he confessed to five murders, including one by dismemberment. But he applied for asylum, and his deportation was delayed. Under the Biden administration, he was given a work permit. His 2025 capture and removal came only weeks before the inauguration of Virginia’s new governor, Abigail Spanberger, one of whose first acts was to implement what amounts to a sanctuary policy across her state. Under the current policy, this confessed murderer would have been set free to prey on innocent Virginians.

These are just a handful of examples that illustrate the deadly reality of sanctuary policies, which create massive incentives for foreign nationals, including violent criminals, to enter the U.S. illegally and hide behind what has effectively become a taxpayer-funded cloak of invisibility.

This system perverts and corrupts the design and purpose of the original cities of refuge as described in the Bible. Those cities were intended to provide a balance between instant justice and mercy by creating space between those responsible for death, possibly unintentional, and those left to suffer its consequences. They were never intended to give quarter to unrepentant lawbreakers.

Sanctuary as properly understood is not characterized by lawlessness, disorder, or misery, which are often the fruits of bad policy. Such is the case with modern sanctuary policies, which erase our borders, erode our culture, annul federal laws designed to protect us, and lead directly to needless death. It is not too much to say that they are an abomination and that no just nation should tolerate them.

Sean Davis is co-founder and CEO of The Federalist. He received a B.B.A. from Texas Tech University and an M.B.A. from the Wharton School at the University of Pennsylvania. He previously served as the chief financial officer of The Daily Caller, the chief operating officer of Media Trackers, an economic policy adviser for former Texas Governor Rick Perry, and the chief investigator for former U.S. Senator Tom Coburn of Oklahoma.

Reprinted with permission from Imprimis, a publication of Hillsdale College. The opinions expressed in Imprimis are not necessarily the views of Hillsdale College.