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Sanctuary marker (S) at Holyrood Abbey, Royal Mile, Edinburgh Sanctuary marker for Holyrood Abbey, Royal Mile, Edinburgh.jpg
Sanctuary marker (S) at Holyrood Abbey, Royal Mile, Edinburgh
Ajax violates Cassandra's sanctuary at the Palladium: tondo of an Attic cup, ca. 440-430 BCE Aias Kassandra Louvre G458.jpg
Ajax violates Cassandra's sanctuary at the Palladium: tondo of an Attic cup, ca. 440–430 BCE

A sanctuary, in its original meaning, is a sacred place, such as a shrine. By the use of such places as a haven, by extension the term has come to be used for any place of safety. This secondary use can be categorized into human sanctuary, a safe place for people, such as a political sanctuary; and non-human sanctuary, such as an animal or plant sanctuary.


Religious sanctuary

Sanctuary is a word derived from the Latin sanctuarium , which is, like most words ending in -arium , a container for keeping something in—in this case holy things or perhaps cherished people (sanctae/sancti). The meaning was extended to places of holiness or safety, in particular the whole demarcated area, often many acres, surrounding a Greek or Roman temple; the original terms for these are temenos in Greek and fanum in Latin, but both may be translated as "sanctuary". Similar usage may be sometimes found describing sacred areas in other religions. In Christian churches sanctuary has a specific meaning, covering part of the interior, covered below.

Two sanctuaries in Wisconsin

Sanctuary as area around the altar

The sanctuary at St. Mary's Cathedral, Sydney StMarysSanctuary.JPG
The sanctuary at St. Mary's Cathedral, Sydney

In many Western Christian traditions including Catholic, Lutheran, Methodist, and Anglican churches, the area around the altar is called the sanctuary; it is also considered holy because of the physical presence of God in the Eucharist, both during the Mass and in the church tabernacle the rest of the time.

In many churches the architectural term chancel covers the same area as the sanctuary, and either term may be used. [1] In some Protestant churches, the term sanctuary denotes the entire worship area while the term chancel is used to refer to the area around the altar-table.

In many Western traditions altar rails sometimes mark the edge of the sanctuary or chancel. In the Eastern Orthodox Church, Eastern Catholic Churches of Syro-Malabar Church, Byzantine rite and Coptic Orthodox Churches, the sanctuary is separated from the nave (where worshippers pray) by an iconostasis, literally a wall of icons, with three doors in it. In other Oriental Orthodox traditions, a sanctuary curtain is used.

The back of the church sanctuary at Church of St. Paul and St. Andrew. Churchofstpaulandandrewinterior.jpg
The back of the church sanctuary at Church of St. Paul and St. Andrew.

The terminology that applies the word sanctuary to the area around the altar does not apply to Christian churches alone: King Solomon's temple, built in about 950 BC, had a sanctuary ("Holy of Holies") where the Ark of the Covenant was, and the term applies to the corresponding part of any house of worship. In most modern synagogues, the main room for prayer is known as the sanctuary, to contrast it with smaller rooms dedicated to various other services and functions. (There is a raised bimah in the sanctuary, from which services are conducted, which is where the ark holding the Torah may reside; some synagogues, however, have a separate bimah and ark-platform.)

Sanctuary as a sacred place

In Europe, Christian churches were sometimes built on land considered to be a particularly holy spot, perhaps where a miracle or martyrdom was believed to have taken place or where a holy person was buried. Examples are St. Peter's Basilica in Rome and St. Albans Cathedral in England, which commemorate the martyrdom of Saint Peter (the first Pope) and Saint Alban (the first Christian martyr in Britain), respectively.

The place, and therefore the church built there, was considered to have been sanctified (made holy) by what happened there. In modern times, the Catholic Church has continued this practice by placing in the altar of each church, when it is consecrated for use, a box (the sepulcrum) containing relics of a saint. The relics box is removed when the church is taken out of use as a church. In the Eastern Orthodox Church, the antimension on the altar serves a similar function. It is a cloth icon of Christ's body taken down from the cross, and typically has the relics of a saint sewn into it. In addition, it is signed by the parish's bishop, and represents his authorization and blessing for the Eucharist to be celebrated on that altar.

Human sanctuary

Traditions of Sanctuary

Although the word "sanctuary" is often traced back only as far as the Greek and Roman empires, the concept itself has likely been part of human cultures for thousands of years. The idea that persecuted persons should be given a place of refuge is ancient, perhaps even primordial, deriving itself from basic features of human altruism. In studying the concept across many cultures and times, anthropologists have found sanctuary to be a highly universal notion, one which appears in almost all major religious traditions and in a variety of diverse geographies. "Cities of refuge" as described by the Book of Numbers and Deuteronomy in the Old Testament, as well as the Bedouin idea of nazaala, or the "taking of refuge," indicate a strong tradition of sanctuary in the Middle East and Northern Africa. In the Americas, many native tribes shared similar practices, particularly in the face of invading European powers. Despite tensions between groups, many tribes still offered and received sanctuary, taking in those who had fled their tribal lands or feared persecution by the Spanish, English, and French. [2]

In the classical world, some (but not all) temples offered sanctuary to criminals or runaway slaves. [3] When referring to prosecution of crimes, sanctuary can mean one of the following:

The Church as a Place of Refuge Richard Burchett - Sanctuary (1867) contrasted.jpg
The Church as a Place of Refuge
Church sanctuary
A sacred place, such as a church, in which fugitives formerly were immune to arrest (recognized by English law from the fourth to the seventeenth century). [4] While the practice of churches offering sanctuary is still observed in the modern era, it no longer has any legal effect and is respected solely for the sake of tradition. [5]
Political sanctuary
Immunity to arrest afforded by a sovereign authority. The United Nations has expanded the definition of "political" to include race, nationality, religion, political opinions and membership or participation in any particular social group or social activities. People seeking political sanctuary typically do so by asking a sovereign authority for asylum.

Right of asylum

Remains of one of four medieval stone boundary markers for the sanctuary of Saint John of Beverley in the East Riding of Yorkshire St John of Beverley Sanctuary Stone.jpg
Remains of one of four medieval stone boundary markers for the sanctuary of Saint John of Beverley in the East Riding of Yorkshire

Many ancient peoples recognised a religious right of asylum, protecting criminals (or those accused of crime) from legal action and from exile to some extent. This principle was adopted by the early Christian church, and various rules developed for what the person had to do to qualify for protection and just how much protection it was.

In England, King Æthelberht made the first laws regulating sanctuary in about AD 600, though Geoffrey of Monmouth in his Historia Regum Britanniae (c. 1136) says that the legendary pre-Saxon king Dunvallo Molmutius (4th/5th century BC) enacted sanctuary laws in the Molmutine Laws as recorded by Gildas (c. 500–570). [6] By Norman times, there had come to be two kinds of sanctuary: All churches had the lower-level kind, but only the churches the king licensed had the broader version. The medieval system of asylum was finally abolished entirely in England by James I in 1623. [7]

Political asylum

During the Wars of the Roses of the 15th century when the Lancastrians or Yorkists would suddenly gain the upper hand by winning a battle, some adherents of the losing side might find themselves surrounded by adherents of the winning side and unable to return to their own side, so they would rush to sanctuary at the nearest church until it was safe to leave it. A prime example is Queen Elizabeth Woodville, consort of Edward IV of England.

In 1470, when the Lancastrians briefly restored Henry VI to the throne, Edward's queen was living in London with several young daughters. She moved with them into Westminster Abbey for sanctuary, living there in royal comfort until Edward was restored to the throne in 1471 and giving birth to their first son Edward during that time. When King Edward IV died in 1483, Elizabeth (who was highly unpopular with even the Yorkists and probably did need protection) took her five daughters and youngest son (Richard, Duke of York; Prince Edward had his own household by then) and again moved into sanctuary at Westminster Abbey. She had all the comforts of home; she brought so much furniture and so many chests that the workmen had to break holes in some of the walls to move everything in fast enough to suit her.[ citation needed ]

In the 20th century, during World War I, all of Russia's Allies made the controversial decision in 1917 to deny political sanctuary to Tsar Nicholas II Romanov and his immediate family when he was overthrown in that year's February Revolution because of his abuses of power and forced to abdicate in March in favor of Alexander Kerensky's Russian Provisional Government. Nicholas and his family and remaining household were sent to Tobolsk, Siberia that summer while Kerensky kept Russia in the war when it couldn't win, enabling Lenin and his Bolsheviks to gain the Russian people's support in overthrowing Kerensky in that year's October Revolution. The Russian Civil War started that November and in July, 1918, with Lenin losing the civil war, Nicholas and his family were executed on Lenin's orders while confined to the Ipatiev House in Yekaterenburg. In 1939, months before World War II began, 937 Jewish refugees from Nazi Germany on board the MS St. Louis met the same fate, first by Cuba—their original destination—and afterwards by the United States and Canada. As a result, 620 of them were forced back to Europe, where 254 of them died in Nazi concentration camps during the war. This incident was the subject of Gordon Thomas' and Max Morgan-Witts' 1974 novel, Voyage of the Damned and its 1976 movie adaptation. In 1970, Simonas Kudirka was denied U.S. sanctuary when he attempted to defect from the then-Soviet Union by jumping from his "mother ship", 'Sovetskaya Litva', onto the USCGC Vigilant when it was sailing from New Bedford while Kudirka's ship was anchored at Martha's Vineyard. Kudrika was accused of stealing 3,000 rubles from Sovetskaya Litva's safe and when the U.S. State Department failed to help him, Kudrika was sent back to the Soviet Union, where he was convicted of treason and sentenced to ten years of hard labor but because Kudirka could claim American citizenship through his mother, he was allowed to return to the United States in 1974. His plight was the subject of Algis Ruksenas' 1973 book Day of Shame: The Truth About The Murderous Happenings Aboard the Cutter Vigilant During the Russian-American Confrontation off Martha's Vineyard and the 1978 TV movie The Defection of Simas Kudirka, starring Alan Arkin. Ten years later, Ukrainian youth, Walter Polovchak, became a cause célèbre in the 1980s because of his request in 1980 at age 12 to remain in the United States permanently after announcing that he didn't want to return with his parents to what was then Soviet Ukraine, and was the subject of a five-year struggle between U.S. and Soviet courts over his fate, which was decided in his favor in 1985 when Walter turned 18 that October 3 and was no longer a juvenile and thus no longer required to return to his parents if he didn't want to. Later in the 1980s, Estonian national and alleged Nazi war criminal, Karl Linnas, was the target of several sanctuary denials outside the United States before he was finally returned in 1987 to the then-USSR to face a highly likely death penalty for alleged war crimes that he was convicted of in 1962 (see Holocaust trials in Soviet Estonia). Linnas died of a heart attack in a Leningrad prison hospital on July 2, 1987 while waiting for a possible retrial in Gorbachevian courts, 25 years after Khrushchevian courts convicted him in absentia.

Sanctuary versus asylum

The concepts of sanctuary and asylum are defined very similarly at their most basic level. Both terms involve the granting of safety or protection from some type of danger, often implied to be a persecuting, oppressive power. The divergence between these terms stems primarily from their societal associations and legal standing; while asylum understood in its political sense implies legally-binding protection on the part of a state entity, sanctuary often takes the form of moral and ethical activism that calls into question decisions made by the institutions in power. [8]

In many instances, sanctuary is not incorporated into the law, but operated in defiance of it. Efforts to create sanctuary for the persecuted or oppressed are often undertaken by organizations, religious or otherwise, who work outside of mainstream avenues to ameliorate what they see as deficiencies in existing policy. Though these attempts to provide sanctuary have no legal standing, they can be effective in catalyzing change at community, local, and even regional levels. Sanctuary can also be integrated into these levels of government through "Sanctuary bills," which designate cities and sometimes states as safe spaces for immigrants deemed "illegal" by the federal government. These bills work to limit the cooperation of local and regional governments with the national government's efforts to enforce immigration law. In recognition of their progressiveness and boldness in the face of perceived injustice, "Sanctuary bills" are commonly referred to as "activist law." [9]

Sanctuary in contemporary society

For the last few centuries, it has become less common to invoke sanctuary as a means of protecting persecuted peoples. Yet, the 1980s saw a massive resurgence of cases as part of the U.S.-Central American sanctuary movement. This resurgence was part of a broader anti-war movement that emerged to protest U.S. foreign policy in Central America. The movement grew out of the sanctuary practices of political and religious organizations in both the United States and Central America. It was initially sparked by immigrant rights organizations in well-established Central American communities. These organizations first opposed U.S. foreign policy in Central America and then shifted towards aiding an ever-increasing number of Central Americans refugees. Working in tandem, immigrant rights organizations and churches created many new organizations that provided housing and legal services for newly arrived immigrants.These organizations also advocated for the creation of sanctuary spaces for those fleeing war and oppression in their home countries. By 1987, 440 cities in the United States had been declared "sanctuary cities" open to migrants from civil wars in Central America. [10]

The immigrant-religious organization partnerships of the sanctuary movement remain active, providing essential services to immigrant populations. Particularly notable in recent years is their legal and advocacy work. By providing legal representation to asylum seekers who may not be able to afford it, these organizations give their clients a better chance of winning their respective cases. As of 2008, detained asylum seekers with legal representation were six times more likely to win their cases for asylum, and non-detained asylum seekers with representation were almost three times more likely to win asylum compared with those without it. [2] The pro bono legal services provided by these organizations also work to alleviate stress on an adjudication system that is already overloaded with cases—a 2014 study of the system showed that about 250 asylum officers at any one time are tasked with interviewing an average of 28,000 asylum seekers. [11] These sanctuary-based organizations also engage in larger-scale advocacy work that allows them to reach immigrant populations beyond the communities they work in. According to a study done by the "New Sanctuary Movement" organization, at least 600,000 people in the United States have at least one family member in danger of deportation. [12] Legislative and judicial advocacy work at the regional and even national level allows organizations to support this group of people by influencing policy.

From the 1980s continuing into the 2000s, there also have been instances of immigrant rights organizations and churches providing "sanctuary" for short periods to migrants facing deportation in Germany, France, Belgium, the Netherlands, Norway, Switzerland, Australia and Canada, among other nations. In 2007, Iranian refugee Shahla Valadi was granted asylum in Norway after spending seven years in church sanctuary after the initial denial of asylum. [13] From 1983 to 2003 Canada experienced 36 sanctuary incidents. [14] In 2016, an Icelandic church declared that they would harbor two failed asylum seekers who violated the Dublin Regulation, and police removed them for deportation, as ecclesiastical immunity has no legal standing. [15]

Other uses

When referring to a shelter from danger or hardship, sanctuary can mean one of the following:

Shelter sanctuary
A place offering protection and safety; a shelter, typically used by displaced persons, refugees, and homeless people.
Humanitarian sanctuary
A source of help, relief, or comfort in times of trouble typically used by victims of war and disaster.
Institutional sanctuary
An institution for the care of people, especially those with physical or mental impairments, who require organized supervision or assistance.

The term "sanctuary" has further come to be applied to any space set aside for private use in which others are not supposed to intrude, such as a "man cave".

Non-human sanctuary

Animal sanctuary

An animal sanctuary is a facility where animals are brought to live and be protected for the rest of their lives. Unlike animal shelters, sanctuaries do not seek to place animals with individuals or groups, instead maintaining each animal until its natural death.

Plant sanctuary

Plant sanctuaries are areas set aside to maintain functioning natural ecosystems, to act as refuges for species and to maintain ecological processes that cannot survive in most intensely managed landscapes and seascapes. Protected areas act as benchmarks against which we understand human interactions with the natural world.

See also

Related Research Articles

A refugee, generally speaking, is a displaced person who has crossed national boundaries and who cannot or is unwilling to return home due to well-founded fear of persecution. Such a person may be called an asylum seeker until granted refugee status by the contracting state or the United Nations High Commissioner for Refugees (UNHCR) if they formally make a claim for asylum. The lead international agency coordinating refugee protection is the United Nations Office of the UNHCR. The United Nations has a second office for refugees, the United Nations Relief and Works Agency (UNRWA), which is solely responsible for supporting the large majority of Palestinian refugees.

Altar rail

The altar rail is a low barrier, sometimes ornate and usually made of stone, wood or metal in some combination, delimiting the chancel or the sanctuary and altar in a church, from the nave and other parts that contain the congregation. Often a gate, or just a gap, at the centre divides the line into two parts. Rails are a very common, but not inevitable, feature of Roman Catholic, Anglican, Lutheran, and Methodist churches. They are usually about two feet 6 inches high, with a padded step at the bottom, and designed so that the wider top of the rail can support the forearms or elbows of a kneeling person.

An asylum seeker is a person who leaves their country of residence, enters another country and applies for asylum in this other country. An asylum seeker is an immigrant who has been forcibly displaced and might have fled their home country because of war or other factors harming them or their family. If their case is accepted, they become considered a refugee. The terms asylum seeker and refugee are often confused.

A safe house is, in a generic sense, a secret place for sanctuary or suitable to hide people from the law, hostile actors or actions, or from retribution, threats or perceived danger. It may also be a metaphor.

Right of asylum Juridical concept in which someone persecuted by their country may take refuge in another

The right of asylum is an ancient juridical concept, under which a person persecuted by one's own country may be protected by another sovereign authority, such as another country or church official, who in medieval times could offer sanctuary. This right was recognized by the Egyptians, the Greeks, and the Hebrews, from whom it was adopted into Western tradition. René Descartes fled to the Netherlands, Voltaire to England, and Thomas Hobbes to France, because each state offered protection to persecuted foreigners.

Immigration to Germany refers to the movement of non-German citizens to Germany. Since 1990, Germany has consistently ranked as one of the five most popular destination countries for immigrants in the world. As of 2019, around 13.7 million people living in Germany, or about 17% of the population, are first-generation immigrants. The majority of immigrants in Germany are from Eastern Europe, Southern Europe and the Middle East.

Cities of Refuge Six Levitical towns in the Kingdom of Israel and the Kingdom of Judah in which the perpetrators of accidental manslaughter could claim the right of asylum

The Cities of Refuge were six Levitical towns in the Kingdom of Israel and the Kingdom of Judah in which the perpetrators of accidental manslaughter could claim the right of asylum. Maimonides, invoking talmudic literature, expands the city of refuge count to all 48 Levitical cities. Outside of these cities, blood vengeance against such perpetrators was allowed by law. The Bible names the six cities as being cities of refuge: Golan, Ramoth, and Bosor, on the east of the Jordan River, and Kedesh, Shechem, and Hebron on the western (right) side.

The Sanctuary movement was a religious and political campaign in the United States that began in the early 1980s to provide safe haven for Central American refugees fleeing civil conflict. The movement was a response to federal immigration policies that made obtaining asylum difficult for Central Americans.

Asylum in the United States Overview of the situation of the right for asylum in the United States of America

The United States recognizes the right of asylum for individuals as specified by international and federal law. A specified number of legally defined refugees who either apply for asylum from inside the U.S. or apply for refugee status from outside the U.S., are admitted annually.

Jeffry A. House is a retired lawyer who practiced in Toronto, Ontario, Canada. He is best known for his efforts on behalf and representation of fugitive American soldiers and Indigenous protesters.

Elvira Arellano is an international activist who works to defend the human rights of immigrants living in the U.S. without legal authorization.

Sanctuary city refers to municipal jurisdictions, typically in North America, that limit their cooperation with the national government's effort to enforce immigration law. Leaders of sanctuary cities say they want to reduce fear of deportation and possible family break-up among people who are in the country illegally, so that such people will be more willing to report crimes, use health and social services, and enroll their children in school. In the United States, municipal policies include prohibiting police or city employees from questioning people about their immigration status and refusing requests by national immigration authorities to detain people beyond their release date, if they were jailed for breaking local law. Such policies can be set expressly in law or observed in practice, but the designation "sanctuary city" does not have a precise legal definition. The Federation for American Immigration Reform estimated in 2018 that 564 U.S. jurisdictions, including states and municipalities, had adopted sanctuary policies.

In ancient Greece and Rome, an asylum referred to a place where people facing persecution could seek refuge. These locations were largely religious in nature, such as temples and other religious sites. A similar concept, the Cities of Refuge, existed in the ancient Levant.

The Central American Resource Center (CARECEN) are two community-based organizations that seek to foster the comprehensive development of the Latino community. CARECEN in the Washington, D.C. metropolitan region was founded in 1981 to protect the rights of refugees arriving from conflict in Central America and to help ease their transition by providing legal services. CARECEN provides direct services in immigration, housing and citizenship while also promoting empowerment, civil rights advocacy and civic training for Latinos. Another CARECEN is also located in Los Angeles and which was established two years after the D.C. location.

LGBT migration is the movement of lesbian, gay, bisexual, transgender, and queer (LGBT) people around the world and domestically, often to escape discrimination or ill treatment due to their sexuality. Globally, many LGBT people attempt to leave discriminatory regions in search of more tolerant ones.

The right of asylum for victims of political persecution is a basic right stipulated in the Constitution of Germany. In a wider sense, the right of asylum recognises the definition of 'refugee' as established in the 1951 Refugee Convention and is understood to protect asylum seekers from deportation and grant them certain protections under the law. Generally, these protections are a part of the asylum procedure itself and are verified by the Federal Office For Migration and Refugees without any further application.

American Baptist Churches v. Thornburgh 760 F. Supp. 796, formerly American Baptist Churches v Meese, is a settlement reached on January 31, 1991, that resulted from a class action lawsuit against the Immigration and Naturalization Service (INS), the Executive Office for Immigration Review (EOIR), and the Department of State. (DOS). The suit was filed in 1985 by a coalition of religious organizations, refugee legal assistance organizations, and numerous human rights organizations, including the American Civil Liberties Union (ACLU), the Center for Constitutional Rights (CCR), and the National Lawyers Guild.(NLG) Although the case originally stated two different groups of plaintiffs, various religious organizations involved in the Sanctuary movement and Central American refugees, after changes were made to criminal laws formerly used to prosecute these religious organizations, the focus of the suit was centered more specifically to claims of discrimination against Central American refugees in asylum seeking processes. This, they argued, was in direct violation of the tenets of the Refugee Act of 1980, which sought to create uniform criteria by which to review cases in which individuals fleeing political persecution and humanitarian crises would become eligible for asylum. After five years, the settlement secured temporary protected status (TPS) for many Salvadoran and Guatemalan immigrants, providing them with among other things, de novo asylum interviews, stays from deportation and work authorization.

The term Flüchtlingspolitik, refers to the legal provisions and the handling of refugees and asylum seekers wanting to enter a country, and/or subsequently staying there for a long period of time.

Francisco Aguirre-Velasquez is an activist for the rights of workers and immigrants in Portland, Oregon. He is originally from El Salvador, but fled the country due to military violence against his family. He has fought for the rights of laborers in both Los Angeles, California and Portland for over 10 years. He was one of the founding members of the Portland organization, Portland VOZ Worker's Education Project, and currently works as the center coordinator for their NE Portland location.

Immigration policy in Texas

The state of Texas has a long history of immigration and immigration policy. The region that is now Texas was originally home to several Native American tribes. The first European immigrants arrived in the 1600s when the land was colonized by the French and the Spanish. Financial incentives created by the Mexican government brought many immigrants to Mexican Texas in the 1820s, mostly from slaveholding areas in the southern United States. This continued as significant illegal immigration to Mexico after 1830, when American migrants were banned.


  1. Robinson, Gary (2006). Architecture. Lotus Press. p. 40. ISBN   9788189093129. In the historic floor plan, the words chancel and sanctuary are often synonymous.
  2. 1 2 Rabben, Linda (2016). Sanctuary and Asylum: A Social and Political History. University of Washington Press. ISBN   978-0-295-99914-2.
  3. Ciappara, Frans (1985). "Non gode l'immunita ecclesiastica" (PDF). Melita Historica. 9 (2): 117–132. Archived from the original (PDF) on 16 April 2016.
  4. "Sanctuary, Violence, and Law in Late Medieval England - Events". Worldwide Universities Network.
  6. Geoffrey of Monmouth, Historia Regum Britanniae 2, 17
  7. "English Coroner System Part 4: Sanctuary". Encyclopædia Britannica Online .
  8. United Nations Conference of Plenipotentiaries on the Status of Refugees and Stateless Persons. United Nations. 1951. OCLC   250576716.
  9. Vannini, Sara; Gomez, Ricardo; Carney, Megan; Mitchell, Katharyne (2018-12-01). "Interdisciplinary Approaches to Refugee and Migration Studies". Migration and Society. 1 (1): 164–174. doi: 10.3167/arms.2018.010115 . ISSN   2574-1306.
  10. Perla, Hector; Coutin, Susan Bibler (2010). "Legacies and Origins of the 1980s US–Central American Sanctuary Movement". Refuge. 26 (1): 7–19. doi: 10.25071/1920-7336.30602 . Retrieved 2020-05-16.
  11. Schoenholtz, Andrew Ian. Lives in the balance : asylum adjudication by the Department of Homeland Security. ISBN   978-0-8147-0877-4. OCLC   995330858.
  12. "Immigration Activist Arrested Outside L.A. Church". Associated Press. Aug 20, 2007. Archived from the original on August 20, 2007 via Library of Congress Web Archives.
  13. "Iranian given asylum in Norway". .
  14. Randy K. Lippert (2005). Sanctuary, Sovereignty, Sacrifice: Canadian Sanctuary Incidents, Power and Law. ISBN   0-7748-1249-4.
  15. "Asylum seekers dragged out of church by Reykjavik Police".

Further reading