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Principle ethics are those concerning things such as respecting others and their freedom of choice for their own futures, while consequence ethics refers more to the results of an action defining whether the actions that caused them were good or bad and that choices are better when they bring more consequences.

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Saturday Night Live created an ad perfect for liberals upset over the 2016 election results. Check it out and see if you don't laugh out loud:

Ericka Andersen - Ericka Andersen is a freelance writer and the digital-marketing director at the Independent Women's Forum. Her first book,Leaving Cloud 9: The True Story of a Life Resurrected From the Ashes of Poverty, Trauma and Mental Illness, is available for pre-order.

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WATCH: SNL's Fake Ad for Sanctuary City For Liberals Is Actually Perfect | National Review

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Saturday Night Live created an ad perfect for liberals upset over the 2016 election results. Check it out and see if you don't laugh out loud: https://www.youtube.com/embed/vKOb-kmOgpI

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Advocates of tougher immigration rules were quick to blame the city for its policy of not cooperating with federal immigration agencies to hold and report potentially dangerous undocumented residents.
RELATED: FOLLOW THE TRIAL HERE
President Trump helped stir national outrage during his presidential campaign last year, repeatedly invoking Steinle's death.

"Countless innocent American lives have been stolen because our politicians have failed in their duty to secure our borders and enforce our laws like they have to be enforced," he told a cheering crowd in Phoenix, Arizona, last August. "(One) victim is Kate Steinle. Gunned down in the sanctuary city of San Francisco, by an illegal immigrant, deported five previous times. And they knew he was no good."

Suggestions for nonfiction analysis, writing/discussion prompts and multimedia projects. Browse our lesson plan collection here.

Sanctuary cities have long been in Trump's crosshairs. The term refers to the scores of cities and counties across the United States that limit their cooperation with federal immigration authorities by refusing most requests to detain, pursue or report undocumented immigrants (those here illegally) who have had contact with local law enforcement.

Just days after taking office, Trump signed a sweeping executive order making good on his key campaign pledge to crack down on illegal immigration. In addition to authorizing the construction of a border wall with Mexico and beefing up immigration enforcement, the order also threatens to cut billions of dollars in federal funds from so-called sanctuary cities.

"Sanctuary jurisdictions across the United States willfully violate Federal law in an attempt to shield aliens from removal from the United States," the order states. It warns that those jurisdictions that don't comply with federal immigration enforcement efforts will lose federal funding. "These jurisdictions have caused immeasurable harm to the American people and to the very fabric of our Republic."

Trump's order instructs federal immigration authorities to target a broader group of immigrants for deportation. It calls for the removal of immigrants "who have committed acts that constitute a chargeable criminal offense" or pose a public safety risk.

In response to Trump's election victory in November, mayors and police chiefs in more than 10 major cities, including San Francisco, Oakland, Los Angeles, New York, Chicago and Washington, D.C., reaffirmed their commitment to upholding sanctuary policies, and have continued to stand by those positions in the face of the recent order.

"We'll proudly stand as a sanctuary city -- protecting our residents from what we deem unjust federal immigration laws -- fight all forms of bigotry and advance our commitment to equity even more passionately," Oakland Mayor Libby Schaaf stated shortly after the election.

San Francisco Mayor Ed Lee reiterated that sentiment on Jan. 26 in his State of the City address: "We are a sanctuary city now, tomorrow, forever."

On Jan. 31, San Francisco became the first city to sue Trump over his order to defund sanctuary jurisdictions. The lawsuit argues that the order is an unconstitutional overreach of the president's power, in violation of the 10th Amendment, which it says protects the sovereignty of local jurisdictions.

"President Trump's executive order tries to turn city and state employees into federal immigration officers. That is unconstitutional," San Francisco City Attorney Dennis Herrera said when announcing the suit. "No president can commandeer the local police force and turn it into the deportation arm of the federal government."

San Francisco receives nearly $500 million a year in federal funds, which would be at risk if Trump's order survives in court.

Although U.S. Immigration and Customs Enforcement (ICE) relies on local authorities to help enforce immigration laws, a 2013 federal appeals court decision concluded that those local agencies are not legally required to detain undocumented immigrants when requested to do so.

An estimated 11 million undocumented immigrants currently reside in the United States.

What are sanctuary cities?

There's no official legal definition, and what it means varies from place to place. Generally speaking, local law enforcement in sanctuary cities or counties don't ask or report the immigration status of people they come into contact with.

A sanctuary jurisdiction typically refuses requests from federal immigration authorities to detain undocumented immigrants apprehended for low-level offenses. For example, when someone gets arrested for a DUI, he or she might spend the night in jail, get processed and then released. If this person is undocumented, though, federal immigration authorities would be alerted and may ask local officials to hold this person for longer, and possibly deport them. A city or county with a sanctuary policy would generally deny that request unless legally mandated to do so.

How many sanctuary cities are there?

Depends who you ask.

A 2006 Congressional Research Service report listed 32 counties and cities with explicit sanctuary ordinances. A number of cities have adopted similar resolutions since then, including Berkeley, Oakland and East Palo Alto.

In an analysis of data from the Immigrant Legal Resource Center, the New York Times tallied 39 cities and 364 counties across the country that in some way limit how much local law enforcement can cooperate with federal detention requests. It's unclear, however, how much action some of these jurisdictions have taken, other than officially expressing opposition to what they consider harsh federal or state immigration laws.

And organizations in some municipalities even challenge the label. In 2011, for instance, the Los Angeles Times editorial board denied that Los Angeles was a sanctuary city, even though in 1979 the city had enacted a measure to keep local police from inquiring about the immigration status of those arrested, one of the first cities in the country to do so.

Four states -- California, Rhode Island, Vermont and Connecticut -- have also enacted ordinances in recent years that limit compliance with federal immigration officials.

A least nine Oregon counties in 2014 stopped complying with ICE requests to hold undocumented immigrants in jail for the sole purpose of deportation. The change came after a federal judge ruled that one of those counties violated a woman's Fourth Amendment rights by detaining her without probable cause. Some legal experts say the ruling may spur more local sanctuary policies across the state and possibly nationwide.

Are sanctuary cities more dangerous?

On the campaign trail, and now as president, Trump has consistently claimed that sanctuary cities "breed crime" and have resulted in "so many needless deaths," with the underlying suggestion that undocumented immigrants are more prone to violent criminal activity.

The language in his recent executive order underscores this:

"Many aliens who illegally enter the United States and those who overstay or otherwise violate the terms of their visas present a significant threat to national security and public safety."

Crime statistics, however, suggest otherwise.

A recent analysis of FBI crime data by UC San Diego political science professor Tom Wong found that most counties considered "sanctuary" jurisdictions have notably lower rates of all types of crime, including homicide, than comparable non-sanctuary counties. In 2015, large metro sanctuary counties had 654 crimes fewer crimes per 100,000 people than large central metro non-sanctuary counties, the report found. That's nearly 15 percent less crime in sanctuary counties.

In smaller counties, the discrepancy was similar. The main exception, the report found, was in medium metro areas and counties bordering on large metro areas, where crime rates in sanctuary jurisdictions were slightly higher.

The report, it should be noted, was published by the Center for American Progress, a progressive policy organization. And it shows correlation, not causation. In other words, there no definitive proof that sanctuary policies actually cause lower crime rates (it could just be a coincidence).

Another study by the American Immigration Council, a pro-immigrant group, analyzed FBI and census data from 1980 through 2010. It found that among men ages 18 to 49, immigrants (both legal and illegal) were far less likely than native-born Americans to engage in criminal behavior or to be incarcerated.

Now keep in mind that both of these studies were conducted by left-leaning organizations with progressive agendas. And even though the conclusions are based squarely on federal statistics, skeptics are likely to counter that the authors used selective data to produce desired results.

Nevertheless, several national policing associations seem to have embraced these findings. As the Washington Post recently reported, the Major Cities Chiefs Association, representing the 63 largest urban areas in the nation, stated in a 2006 report, that "immigration enforcement by local police would likely negatively affect and undermine the level of trust and cooperation between local police and immigrant communities," which would "would result in increased crime against immigrants and in the broader community, create a class of silent victims and eliminate the potential for assistance from immigrants in solving crimes or preventing future terroristic acts."

The International Association of Chiefs of Police reiterated this position, writing that "state and local law enforcement should not be involved in the enforcement of civil immigration laws since such involvement would likely have a chilling effect on both legal and illegal aliens reporting criminal activity or assisting police in criminal investigations."

Which California cities have "sanctuary" policies?
Note: Although some of these cities may not explicitly identify as "sanctuary cities," they've all adopted some type of policy (an ordinance, resolution or law enforcement directive) that limits how much local law enforcement officials can cooperate with federal immigration enforcement efforts. This is not necessarily a complete list - it only includes those cities for which official documentation could be found.
What's the history?

The roots of the modern sanctuary movement date back to the 1980s. U.S. churches, synagogues and other religious institutions began to provide refuge and services to thousands of undocumented immigrants from Guatemala and El Salvador who had fled civil unrest at home but were denied sanctuary in the U.S., largely due to Cold War politics.

The effort became known as the Sanctuary Movement, and as it spread, a number of cities throughout the country joined in solidarity, passing resolutions to overlook the immigration status of residents.

What are the arguments for and against these policies?

Supporters argue that cities have bigger public safety priorities and too few resources to handle immigration enforcement. Additionally, many local policymakers and law enforcement agencies argue that immigration enforcement is not their responsibility, and that cracking down on undocumented residents would undermine community relations, disrupt services and dissuade those residents from cooperating with crime prevention effort. They also note that none of their protective policies in any way prevent local police from pursuing immigrants suspected of committing crimes.

Trump is among a large number of mostly Republicans opposed to sanctuary policies, arguing that they encourage illegal immigration, undermine federal enforcement efforts and severely compromise public safety, resulting in crimes that could have been avoided through deportation.

What's unique about San Francisco's law?

Although the majority of sanctuary cities don't ask residents about their immigration status and refuse to share information with Immigration and Customs Enforcement (ICE), San Francisco is among a handful of localities that take things a bit further.

The City and County of Refuge ordinance, adopted in 1989, prohibits the city from using any "funds or resources to assist in the enforcement of federal immigration law or to gather or disseminate information regarding the immigration status" of residents unless explicitly required by federal or state law or court order.

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How the Kate Steinle Murder Case Thrust Sanctuary Cities into the National Spotlight

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Advocates of tougher immigration rules were quick to blame the city for its policy of not cooperating with federal immigration agencies to hold and report potentially dangerous undocumented residents. RELATED: FOLLOW THE TRIAL HERE President Trump helped stir national outrage during his presidential campaign last year, repeatedly invoking Steinle's death.

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This cartoon makes the point that by allowing sanctuary cities to overcome immigration laws, criminals are allowed easy access back to the public with others who could potentially be hurt or killed as a result.

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This cartoon is shining a negative light on Democrats who are defending San Francisco as a sanctuary city when the immigrants it protects include criminals who don't deserve it.

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If the next president's immigration agenda includes a pitched battle over "sanctuary" cities, a term Donald Trump uses with disgust, the proper response from places like New York will be: Bring it on.

The word "sanctuary" as Mr. Trump deploys it - a place where immigrant criminals run amok, shielded from the long arm of federal law - is grossly misleading, because cities with "sanctuary" policies cannot obstruct federal enforcement and do not try to. Instead, they do what they can to welcome and support immigrants, including the unauthorized, and choose not to participate in deportation crackdowns they see as unjust, self-defeating and harmful to public safety.

New York City wears that kind of "sanctuary" label proudly. As California considers bold steps to shield its residents from a possible Trump immigration assault, the New York City Council has already built its own strong web of protections. A groundbreaking City Council program has provided free legal representation for children who fled violence in Central America and arrived unaccompanied at the border. Of 1,265 cases accepted under the program, 72 children were granted asylum and 55 obtained lawful permanent residency. The Council has expanded health and legal services in immigrant communities. And it passed bills to keep federal immigration agents out of the Rikers Island jails, and to forbid city police and corrections officers from detaining suspects for deportation, unless there is a judge's warrant.

Mayor Bill de Blasio, who signed both bills, has also promised since the election to defend immigrant residents from other possible threats, like a registry of Muslims and a roundup of unauthorized immigrants. The city will stop saving the personal records of residents who apply for its municipal ID card, to prevent the data from being abused for a deportation purge.

Gov. Andrew Cuomo has echoed these sentiments, promising, though without specifics, that New York State will begin expanding legal assistance for immigrants in the coming year. The effort will be welcome should Mr. Trump begin to lower the boom on unauthorized immigrants - though it's impossible to know the details of what he will do, given the volatility and imprecision of his many immigration-related threats and promises.

Whatever forms the purge takes, the sanctuary forces will have to be resolute in opposition. One good thing: New York and its allies in cities across the country, in governments, schools and churches, will have the public on their side. A recent Global Strategy Group poll found that Americans oppose, 58 percent to 28 percent, repealing President Obama's DACA program, which shields the young immigrants called Dreamers from deportation. A Quinnipiac poll taken after the election found that Americans strongly support - 72 percent to 25 percent - allowing unauthorized immigrants to stay, with 60 percent supporting a path to citizenship. This support is higher than at any point in the four years it has been asking the question, Quinnipiac said.

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If the next president's immigration agenda includes a pitched battle over "sanctuary" cities, a term Donald Trump uses with disgust, the proper response from places like New York will be: Bring it on.

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Sanctuary Cities Have a Legal Right to Defy the Federal Government

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The Supreme Court has ruled that law enforcement decisions fall to the jurisdiction with the most expertise. Local governments also have the constitutional authority to grant their residents more rights and protections.

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Lucia Quiej joins demonstrators on Nov. 16 to rally against President-elect Donald Trump, asking that the city of Homestead, Florida, be a sanctuary city. | Getty

At least three dozen so-called sanctuary cities across the country are standing firm against President-elect Donald Trump's pledge to crack down on them, according to a POLITICO analysis.

Trump has pledged that one of the top priorities for his first 100 days in office is to "cancel all federal funding to sanctuary cities," an unspecific term for jurisdictions that limit, in one way or another, their cooperation with federal immigration enforcement agents.

Story Continued Below

But with six weeks to go until the inauguration, POLITICO identified not one city that is reconsidering its "sanctuary" policies - such as not asking residents about their immigration status or detaining people solely because of that status - on account of the presidential election.

Instead, officials in at least 37 cities listed below have doubled down since Trump's election, reaffirming their current policies or practices in public statements, despite the threat of pushback from the incoming administration, and at least four cities have newly declared themselves sanctuary cities since Trump's win. Ten other cities have said they will wait to see what Trump does but are not currently making any changes, according to local news reports and inquiries from POLITICO.

There is no definitive list of U.S. sanctuary cities because of the term's flexible definition. The 47 total sanctuary cities POLITICO identified were compiled from multiple sources, including a 2006 Congressional Research Service report, a 2014 Department of Homeland Security report and a 2016 Department of Justice memo. They range from small towns like Aberdeen, Washington, and Ashland, Oregon, to big cities like New York and San Francisco.

Some city officials just don't take Trump's threat seriously, while others are openly flouting a president-elect they see as hostile to immigrants. Regardless, legal experts say Trump would have a lot of trouble fulfilling his promise to withhold federal funds.

"It depends on how serious they get, but whatever is going to happen, this is going to end up in court," said Bill Ong Hing, a law professor at the University of San Francisco and the founder of the Immigrant Legal Resource Center.

The Trump transition team did not respond to requests for comment.

Most local leaders avoid the ambiguous term "sanctuary city," including Fresno Police Chief Jerry Dyer, who said he thinks it is somewhat of a misnomer because it implies that such cities offer blanket protection from deportation when that is not the case. In reality, Dyer said Fresno's policy limits police officers' cooperation with Immigration and Customs Enforcement, but they, as in almost every other sanctuary city, still must and do cooperate with federal authorities "when it is to assist them with criminal activity other than immigration status."

Dyer doubts that Trump will follow through with his threat to withhold funds - and he's not alone. Leaders of several cities - including Baltimore; Long Beach, California; Mesa, Arizona; and Springfield, Oregon - are satisfied with putting off any conversation about their sanctuary practices until Trump can prove that his funding threat is real. Tyler Gamble, the communications director of the New Orleans Police Department, said the city's current policies have been approved by the Department of Justice, and he sees no reason to speculate on the future.

Legal experts seem to agree that the Trump administration would have a difficult time enacting the type of defunding it wishes to see. The most basic argument against the federal government's ability to do that is nested in the Tenth Amendment. "It's about federalism. It's about separation of powers," Hing said. Phil Torrey, a lecturer at Harvard Law School and the supervising attorney of the Harvard Immigration Project, explained that the Tenth Amendment gives broad powers to the states that include the ability to set policy agendas for local law enforcement, while it gives broad powers to the federal government to decide how to tax and spend dollars. The Supreme Court comes in when these powers collide, and the court has established precedent that the federal government cannot be overly coercive, Torrey said.

One such example is South Dakota v. Dole, a 1987 case that clarified what rules Congress must follow when attaching conditions to federal funds. In that case, the court ruled that the federal government could withhold some highway funding from cities that did not enforce the federal drinking age because it wouldn't be enough money to be considered coercive and because it did not violate the "germaneness rule" since the drinking age condition was determined to be germane to the purpose of the funds: safe interstate travel. That second rule, in particular, will be harder to satisfy with sanctuary cities, Hing argues, because "most federal funds to cities and local governments are not germane to immigration enforcement."

Another relevant Supreme Court ruling is National Federation of Independent Business v. Sebelius, in which the Supreme Court in 2012 ruled unconstitutional a provision of the Affordable Care Act that would have blocked federal Medicaid funding to states that didn't accept Obamacare's proposed Medicaid expansion. Hing suggests that the Supreme Court struck down that provision because it "went too far" and was deemed too coercive.

Torrey said these ruling makes one thing very clear: "What the federal government can't do at this point is basically pull funding wholesale from states and localities in order to get their local law enforcement agents to basically enforce federal immigration law." There are, he noted, some Department of Justice grants set aside for local law enforcement that is arguably related to immigration enforcement and "could be at risk." But Hing said that allotment is equivalent to a drop in the bucket, estimating it to be about $600 million total nationally. For context, San Francisco alone receives more than $1 billion annually in federal funds.

The fact that there's no clear definition of sanctuary cities means it will be all the more difficult for Trump to implement any sort of defunding, Torrey said. "If the federal government is really looking to do this," he said, "they're going to have look at each individual sheriff's office, and I just think that politically that's not going to work, and logistically it doesn't sound tenable at all."

There are other actions besides the withholding of federal funds that the incoming Trump administration could take to reduce the number of sanctuary cities. Jessica Vaughan, director of policy studies for the Center for Immigration Studies, a research group that favors more restrictive immigration laws, said the most basic action the Trump administration could take is to clarify the expectations and obligations of local law enforcement officials. Vaughan said she believes the Obama administration's "ambiguity" on ICE detainer requests has left sheriffs confused about their legal liability if they comply with such requests. (In many cities, the ACLU has pursued litigation against county jails that hold undocumented immigrants without court orders.) Vaughan said Sen. Jeff Sessions, Trump's pick for attorney general, could clarify to those sheriffs that detainer requests are not optional and assure them that they will not face prosecution for assisting ICE.

As for what Vaughan describes as the "most egregious" sanctuary cities - those like Los Angeles or Chicago that openly defy even the Obama administration's immigration enforcement efforts - she said they will likely lose the Justice Department law enforcement grants that Torrey mentioned and might even face prosecution by the department. It is very likely, she suggested, that the legality of their practices will ultimately be decided by a federal court.

Nevertheless, many leaders are ready to remain steadfast. Mayors or police spokespeople from Aberdeen; Princeton, New Jersey; Northampton, Massachusetts; and Las Vegas all told Politico that they have no plans to reassess their current practices. Similarly, in Ashland, the mayor, the city attorney and the police chief all asserted at a city council meeting on Nov. 17 that they have no intention of changing their sanctuary status because of the election. And in Evanston, an ordinance was adopted just last week that promises the city will remain welcoming to immigrants and limit cooperation with federal immigration officials.

In just the past few weeks, several other cities, including Urbana, Illinois; Northfield, Minnesota; and Pittsburgh, have begun to consider taking steps to formally become sanctuaries in defiance of the president-elect. Santa Ana, California, as well as the Vermont cities of Burlington, Montpelier and Winooski, have already passed resolutions to formalize sanctuary city status since the election.

Trump may have lowered the number of immigrants he hopes to deport from "at least 11 million" to "probably 2 million," but even then, his administration will have a steep hill to climb without the cooperation of local law enforcement. The top 10 sanctuary cities by undocumented population (Los Angeles, New York, Chicago, Seattle, Austin, Newark, Denver, Philadelphia, Minneapolis and San Francisco) account for more than 2 million undocumented immigrants.

***
Municipal and police leaders from the following cities have publicly reaffirmed their sanctuary status (even if they don't all accept the "sanctuary city" designation).
Appleton, Wisconsin
Ashland, Oregon
Aurora, Colorado
Austin, Texas
Berkeley, California
Boston, Massachusetts
Cambridge, Massachusetts
Chicago, Illinois
Denver, Colorado
Detroit, Michigan
Evanston, Illinois
Hartford, Connecticut
Jersey City, New Jersey
Los Angeles, California
Madison, Wisconsin
Minneapolis, Minnesota
Nashville, Tennessee
New Haven, Connecticut
New York, New York
Newark, New Jersey
Newton, Massachusetts
Oakland, California
Philadelphia, Pennsylvania
Phoenix, Arizona
Portland, Oregon
Providence, Rhode Island
Richmond, California
San Francisco, California
Santa Fe, New Mexico
Seattle, Washington
Somerville, Massachusetts
St. Paul, Minnesota
Syracuse, New York
Takoma Park, Maryland
Tucson, Arizona
Washington, D.C.
The following cities are reported to have no plans at the moment to change their immigration-related policies or practices.
Aberdeen, Washington
Baltimore, Maryland
Fresno, California
Las Vegas, Nevada
Long Beach, California
Mesa, Arizona
New Orleans, Louisiana
Northampton, Massachusetts
Princeton, New Jersey
Springfield, Oregon
The following cities have formally declared themselves sanctuaries since the presidential election.
Santa Ana, California
Burlington, Vermont
Montpelier, Vermont
Winooski, Vermont

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Sanctuary cities stand firm against Trump

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At least three dozen so-called sanctuary cities across the country are standing firm against President-elect Donald Trump's pledge to crack down on them, according to a POLITICO analysis. Trump has pledged that one of the top priorities for his first 100 days in office is to "cancel all federal funding to sanctuary cities," an unspecific term for jurisdictions that limit, in one way or another, their cooperation with federal immigration enforcement agents.

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President-elect Donald Trump has repeatedly promised to engage in large-scale deportation of undocumented immigrants. In order to accomplish that goal, he is likely to need the cooperation of state and local governments, as federal law enforcement personnel are extremely limited. But numerous cities have "sanctuary" policies under which they are committed to refusing cooperation with most federal deportation efforts. They include New York, Los Angeles, Chicago, Seattle, and other cities with large immigrant populations. Sanctuary cities refuse to facilitate deportation both because city leaders believe it to be harmful and unjust, and because local law enforcement officials have concluded that it poisons community relations and undermines efforts to combat violent crime. They also recognize that mass deportation would have severe economic costs.

Under the Constitution, state and local governments have every right to refuse to help enforce federal law. In cases like Printz v. United States (1997) and New York v. United States (1992), the Supreme Court has ruled that the Tenth Amendment forbids federal "commandeering" of state governments to help enforce federal law. Most of the support for this anti-commandeering principle came from conservative justices such as the late Antonin Scalia, who wrote the majority opinion in Printz.

Trump has said that he intends to break the resistance of sanctuary cities by cutting off all of their federal funding. The cities might continue resisting even if they do lose some federal funds. But Trump's threat is not as formidable as it might seem.

Few if any federal grants to state and local governments are conditioned on cooperation with federal deportation efforts. The Supreme Court has long ruled that conditions on federal grants to state and local governments are not enforceable unless they are "unambiguously" stated in the text of the law "so that the States can knowingly decide whether or not to accept those funds." In ambiguous cases, courts must assume that state and local governments are not required to meet the condition in question. In sum, the Trump administration can't cut off any federal grants to sanctuary cities unless it can show that those grants were clearly conditioned on cooperation with federal deportation policies.

The looming fight over sanctuary cities is an example of how federalism and constitutional limitations on federal power can sometimes protect vulnerable minorities - in this case undocumented immigrants. States and localities have a reputation for being enemies of minority rights, while the federal government is seen as their protector. That has often been true historically. But sometimes the situation is reversed - a pattern that has become more common in recent years.

Many deportation advocates claim it is essential to enforce the law against all violators. But the vast majority of Americans have violated the law at some point in their lives, and few truly believe that all lawbreaking should be punished, regardless of the nature of the law in question or the reason for the violation. And few have more defensible reasons for violating law than undocumented migrants whose only other option is a lifetime of Third World poverty and oppression. In any event, even if there is an obligation to enforce a particular law, it does not follow that the duty falls on state and local governments.

At this point, it is not yet clear how far Trump intends to push his deportation agenda. Election exit polls suggest that mass deportation is not a popular policy, with 70% of the public believing that undocumented migrants working in the US should be offered permanent residency, and only 25% indicating they should be deported. The spectacle of the federal government trying to deport large numbers of people in the face of local resistance is unlikely to make good PR for the Trump administration. Perhaps that will lead them to scale back their ambitions.

Should Trump choose to pursue a policy of mass deportation regardless of the potential downsides, sanctuary cities can refuse to cooperate with it. And they will have the Constitution on their side.

UPDATE: It is worth noting that if Congress were to pass a law stripping sanctuary cities of all their federal funding unless they help facilitate federal deportation efforts, it would be unconstitutional under the Supreme Court's decision striking down the Obamacare Medicaid expansion in NFIB v. Sebelius (2012), which forbids funding conditions so coercive that they amount to a "gun to the head" of a state or local government. While the exact limits of this principle are debatable, denying a state all federal grants for the purpose of compelling cooperation with federal deportation policy surely qualifies, if anything does. At the very least, that would be true for local governments that depend on federal funds for a substantial proportion of their budget.

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Opinion | Federalism, the Constitution, and sanctuary cities

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President-elect Donald Trump has repeatedly promised to engage in large-scale deportation of undocumented immigrants. In order to accomplish that goal, he is likely to need the cooperation of state and local governments, as federal law enforcement personnel are extremely limited. But numerous cities have "sanctuary" policies under which they are committed to refusing cooperation with most federal deportation efforts.

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At a news conference last week, Rahm Emanuel, the mayor of Chicago, tried to reassure undocumented immigrants living in the city. "To all those who are, after Tuesday's election, very nervous and filled with anxiety, you are safe in Chicago," he said. On the campaign trail, Donald Trump had consistently promised to deport immigrants living in this country illegally, but Emanuel, along with other big-city mayors, including Bill de Blasio, in New York, asserted that their cities-so-called sanctuary cities-would remain safe havens against federal deportation actions. As Emanuel went on to declare, "Chicago has in the past been a sanctuary city. . . . It always will be a sanctuary city."

What these mayors didn't say, however, was how their municipalities would be able to prevent the federal government from exerting its authority-and what they mean by the term "sanctuary city."

The American movement to provide sanctuary to undocumented immigrants dates back thirty-four years, to the Southside Presbyterian Church in Tucson, Arizona, where the Reverend John Fife announced that his church would protect refugees fleeing the civil wars in El Salvador and Guatemala. Because the Reagan Administration supported the regimes in those two countries, it was difficult, if not impossible, for Salvadoreans and Guatemalans who felt persecuted by government forces to gain political asylum in the U.S., and harboring them was done in open defiance of the federal government. Between fifty and a hundred people stayed at the church each night, sleeping on foam pads on the floor, or on the carpet in the chapel. Volunteers provided meals, legal assistance, medical care, and English-language classes. Over ten years, Southside Presbyterian harbored thirteen thousand refugees, and some five hundred other congregations across the country ultimately joined the effort. These churches and synagogues physically protected refugees in an act of open civil disobedience.

Today's sanctuary-cities movement shares the convictions of this campaign of the nineteen-eighties, but the means of resistance are quite different. Christopher Lasch, an associate professor at the University of Denver's Sturm College of Law, who has written extensively on sanctuary policies, warns that the term can be misleading: "What people get all wrong is that they hear the word 'sanctuary,' and they think it's about harboring people." Unlike sanctuary churches, sanctuary cities aren't pursuing a public act of subversion but rather a course of non-coöperation, telling their police and jail personnel to refuse assistance to federal immigration authorities in their efforts to deport immigrants.

For the most part, the sanctuary city is a recent phenomenon, a direct response to President Obama's efforts to target undocumented immigrants with criminal records, a policy that led to the deportation of two and a half million during his Administration. Shortly before Obama won the Presidency, in early 2008, Congress approved the Secure Communities Program, under which the fingerprints of anyone charged with a crime are entered into a national database. Immigration and Customs Enforcement, or I.C.E., can ask a local jail to hold an inmate beyond his release date, giving time for the agency to send representatives to take the person into federal custody. These detention requests became the federal government's chief immigration-enforcement tool. (In 2014, Obama replaced Secure Communities with a similar but ostensibly less sweeping program.) An earlier initiative, still in place, gives local police and sheriffs' departments the ability to have officers deputized to enforce immigration law. If a local police officer makes a traffic stop, she can ask the driver about his immigration status and hold him in custody if he is here illegally.

When these measures were instituted, communities across the country resisted. While most turned over illegal immigrants accused of serious crimes, many refused to turn over undocumented immigrants arrested on minor charges. And some refused to have police ask about immigration status in the first place. For some city leaders, the reason was simple: they opposed mass deportations, and they didn't want to have any role in assisting the federal government's efforts. But there were also legal considerations. Some federal courts have ruled that detaining a person beyond his release date amounts to holding someone without a court order, a violation of the Fourth Amendment. There were also practical concerns. Many police departments feared that a policy of arresting people due to their immigration status would discourage victims or witnesses of crimes from coöperating with investigations. Some cities also worried that it would lead to racial profiling. In 2012, there were a few dozen sanctuary communities; today there are around five hundred and fifty.

During his campaign, Trump asserted that on his first day in office he would cut federal funds to sanctuary cities. It's a powerful threat. On CNN's "State of the Union" last Sunday, Reince Priebus confirmed that removing "the criminal elements" and "people that are not good people" is still very high on Trump's early agenda. But none of the sanctuary communities seem to have backed down since the election. If anything, some have become more defiant. Last week, Los Angeles's police chief, Charlie Beck, told the Los Angeles Times, "We are not going to engage in law enforcement activities solely based on somebody's immigration status. We are not going to work in conjunction with Homeland Security on deportation efforts. That is not our job, nor will I make it our job."

Trump has not been clear about how he intends to round up undocumented immigrants with criminal records (nor has he indicated what kind of criminal record would warrant deportation), but the sanctuary cities will undoubtedly complicate those efforts. Without the coöperation of local law enforcement, finding immigrants would be a difficult task. Lasch, the law professor, suggests that, "short of creating a huge deportation force, President Trump won't have any hope of making good on his promise of deporting two to three million people" without the help of local police. Currently, there are only fifty-eight hundred I.C.E. agents nationwide.

Nonetheless, there is only so much protection that sanctuary cities can offer. There's nothing to keep federal agents from, say, conducting a raid at a factory or an individual residence within a sanctuary city.

John Fife, of Southside Presbyterian, is retired now, and I reached him by phone at his home, in Tucson. He told me that over these past couple of weeks he has fielded dozens of phone calls from churches, universities, and cities about the movement of the nineteen-eighties, with callers wanting to know how the sanctuaries worked and how hard it was to actively defy the federal government.

In recounting those years, Fife explained, "We had no middle ground between collaboration and resistance." Fife openly challenged authorities, draping the church in a banner addressing the government: "Immigration: Do not profane the sanctuary of God."

The Reagan Administration, wanting to avoid a public confrontation, never sent federal law enforcement into sanctuary churches. But, in 1985, the Department of Justice did bring criminal-conspiracy charges against sixteen Arizona sanctuary activists, including Fife. Eight were found guilty, though no one served prison time. By 1992, with the peace accords in Central America, the sanctuary movement had run its course. Roughly half a million Central Americans won legal status.

"Folks are asking, 'How can we prepare if we need to protect these families?' " Fife told me. "I tell them what we did. How necessary that will be today, we'll have to wait and see."

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At a news conference last week, Rahm Emanuel, the mayor of Chicago, tried to reassure undocumented immigrants living in the city. "To all those who are, after Tuesday's election, very nervous and filled with anxiety, you are safe in Chicago," he said.